NATIONAL RENEWABLE ENERGY LABORATORY

ENVIRONMENTAL PERFORMANCE REPORT FOR 2009

(Annual Site Environmental Report per DOE Order 231.1-1A Chg 2)

Prepared by:

Environment, Health, and Safety Office

National Renewable Energy Laboratory

NREL is a national laboratory of the

U.S. Department of Energy and is

Operated by the Alliance for Sustainable Energy, LLC

October 2010
NREL Environmental Performance Report- 2009 Page ii

Cover Photo contributed by Bob Fiehweg, 2009 – Siemens Wind Turbine at the National Wind 

Technology Center.

NOTICE

This report was prepared as an account of work sponsored by an agency of the United States 

government. Neither the United States government nor any agency thereof, nor any of their employees, 

makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, 

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that its use would not infringe privately owned rights. Reference herein to any specific commercial product, 

process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute 

or imply its endorsement, recommendation, or favoring by the United States government or any agency 

thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of 

the United States government or any agency thereof.

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NREL Environmental Performance Report- 2009 Page iii

List of Acronyms

AEO Annual Energy Outlook

AFUF Alternative Fuels User Facility

APEN Air Pollution Emission Notice

AST Aboveground storage tank

AWS Alternative Work Schedule

bgs below ground surface

BMP Best Management Practice

BTU British thermal unit

CDPHE Colorado Department of Public Health and Environment

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CGP Construction General Permit

CMS Chemical Management System

CNG Compressed natural gas

CSP Concentrating solar power

CY Calendar Year

DBP Disinfection byproducts

DFD Denver Fire Department

DOE U.S. Department of Energy

DOE-GO Department of Energy Golden Field Office

DSOC District Shops and Operation Center

DWOP Denver West Office Park

EA Environmental Assessment

EHS Environment, Health, and Safety

EIA Energy Information Administration

EISA Energy Independence and Security Act

ELP Environmental Leadership Program

EMS Environmental Management System

EO Executive Order

EPA U.S. Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

ERT Emergency Response Team

ES&H Environment, Safety, and Health

ESH&Q Environment, Safety, Health, and Quality

ESIF Energy Systems Integration Facility

ESPC Energy Savings Performance Contract

FEC Federal Electronics Challenge

FTE Full-time equivalent

FTLB Field Test Laboratory Building

FY Fiscal Year

GH Golden Hill

GHG Greenhouse gas

GSA Government Services Administration

gsf gross square foot

HAAs Haloacetic acids

HABS Historic American Buildings Survey

HAER Historic American Engineering Record

HMIS Hazardous Materials Information System

hp horsepower

HSS U.S. Department of Energy Office of Health, Safety, and Security

IBRF Integrated Biorefinery Research Facilities

IPM Integrated pest management

IRCA International Register of Certificated Auditors
NREL Environmental Performance Report- 2009 Page iv

ISM Integrated safety management

ISMS Integrated Safety Management System

ISO International Organization for Standardization

IUF Industrial User Facility

JSF Joyce Street Facility

Kg kilogram

kW kilowatt

LDRD Laboratory directed research and development program

LEED Leadership in Energy and Environmental Design

LEPC Local Emergency Planning Committee

MAP Mitigation Action Plan

MCL Maximum contaminant level

MRI Midwest Research Institute

MtC/yr Metric tons of carbon per year

mrem millirem (radiation equivalent man)

MW megawatt

MW-hr megawatt-hour 

NEPA National Environmental Policy Act

NESHAP National Emissions Standards for Hazardous Air Pollutants

NOI Notice of intent

NPDES National Pollutant Discharge Elimination System

NREL National Renewable Energy Laboratory

NWTC National Wind Technology Center

ODS Ozone-depleting substances

OTF Outdoor Test Facility

PDU Process Development Unit

ppm parts per million

PV Photovoltaics

PPAs Power Purchase Agreements

PWSID Public Water Supply Identification Number

RAA Running annual average

RCRA Resource Conservation and Recovery Act

RECs Renewable Energy Certificates

RFA Rocky Flats Alluvium

RFHP Renewable Fuel Heat Plant

ReFUEL Renewable Fuels and Lubricants Research Laboratory

RQ Reportable quantity

RSF Research Support Facility

RTD Regional Transportation District

S&TF Science and Technology Facility

SARA Superfund Amendments and Reauthorization Act

SERC State Emergency Response Commission

SERF Solar Energy Research Facility

SERI Solar Energy Research Institute

SHPO State Historic Preservation Officer

SIC Standard industrial classification

SOP Safe operating procedure

SRRL Solar Radiation Research Laboratory

STM South Table Mountain

TCPDU Thermochemical Process Development Unit

TPQ Threshold planning quantity

TTF Thermal Test Facility

TTHM Total trihalomethane

USACE U.S. Army Corps of Engineers

USDA U.S. Department of Agriculture

WHF Waste Handling Facility
NREL Environmental Performance Report- 2009 Page v

TABLE OF CONTENTS

1 Introduction ..........................................................................................................................................1

1.1 Purpose ...............................................................................................................................................1

1.2 Background .........................................................................................................................................1

1.3 Site and Facility Description................................................................................................................3

1.3.1 South Table Mountain Site.........................................................................................................10

1.3.2 National Wind Technology Center.............................................................................................11

1.3.3 Denver West Office Park/Golden Hill ........................................................................................12

1.3.4 Joyce Street Facility....................................................................................................................13

1.3.5 Renewable Fuels and Lubricants Research Laboratory .............................................................13

1.4 Site Environmental Conditions/Features..........................................................................................13

1.4.1 Climate .......................................................................................................................................13

2 Compliance Summary .........................................................................................................................14

2.1 Laws and Regulations........................................................................................................................14

2.1.1 Air Quality Protection ....................................................................................................................14

2.1.2 Drinking Water Quality Protection ............................................................................................14

2.1.3 Groundwater Quality Protection ...............................................................................................14

2.1.4 Wastewater................................................................................................................................14

2.1.5 Surface Water Quality Protection..............................................................................................15

2.1.6 Waste Management ..................................................................................................................15

2.1.7 Storage Tanks.............................................................................................................................15

2.1.8 Threatened and Endangered Species/Species of Concern ........................................................15

2.1.9 EPCRA Compliance and Prevention of Toxic Releases...............................................................16

2.1.10 Cultural Resources Protection .................................................................................................17

2.1.11 Other........................................................................................................................................17

2.2 DOE Order 450.1A, Environmental Protection Program ..................................................................17

2.3 Executive Orders...............................................................................................................................18

2.3.1 Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic 

Performance .......................................................................................................................................18
NREL Environmental Performance Report- 2009 Page vi

2.3.2 Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation 

Management.......................................................................................................................................18

2.3.3 Executive Order 11988, Floodplains Management....................................................................18

2.3.4 Executive Order 11990, Wetlands Protection ...........................................................................18

2.4 Permit Summary ...............................................................................................................................19

3 NREL’s Positive Role in the Environment–Global and Local ...............................................................20

3.1 Energy Policy Updates.......................................................................................................................20

3.2 NREL Research Helping Meet Legislative Goals................................................................................21

3.2.1 General Capabilities...................................................................................................................21

3.2.2 Biofuels.......................................................................................................................................21

3.3 NREL–Research to Reverse Climate Change .....................................................................................21

3.3.1 Wind...........................................................................................................................................22

3.3.2 Concentrating Solar Power ........................................................................................................22

3.3.3 Photovoltaics..............................................................................................................................22

3.4 NREL and the Community .................................................................................................................23

4 Environmental Management System .................................................................................................24

4.1 Policy .................................................................................................................................................25

4.1.1 Significant Aspects.....................................................................................................................26

4.1.2 EMS Effectiveness - Benefits to the Environment and NREL .....................................................26

4.1.3 Notable 2009 Activities..............................................................................................................27

4.1.4 Public Outreach..........................................................................................................................28

4.2 Performance Indicators and Progress...............................................................................................28

4.2.1 2009 Environmental Objectives and Progress toward Goals.....................................................28

4.2.2 State of Colorado ELP Commitments (2007–2010) ...................................................................29

4.2.3 2010 Environmental Objectives.................................................................................................30

4.3 Assessment and Improvement .........................................................................................................31

4.3.1 2009 Assessment Activities........................................................................................................31

4.4 Sustainability and the Environmental Management System............................................................32

4.4.1 2009 Results...............................................................................................................................32

5 Environmental Programs ....................................................................................................................43

5.1 Air Quality Protection .......................................................................................................................43

5.1.1 Program Management...............................................................................................................43
NREL Environmental Performance Report- 2009 Page vii

5.1.2 Permitting ..................................................................................................................................44

5.1.3 2009 Activities............................................................................................................................44

5.2 Drinking Water..................................................................................................................................45

5.2.1 Program Management...............................................................................................................45

5.2.2 Permitting /Notifications ...........................................................................................................46

5.2.3 2009 Activities............................................................................................................................46

5.3 Groundwater.....................................................................................................................................47

5.3.1 Program Management...............................................................................................................47

5.3.2 Permitting ..................................................................................................................................49

5.3.3 2009 Activities............................................................................................................................49

5.4 Wastewater Discharge......................................................................................................................49

5.4.1 Program Management...............................................................................................................49

5.4.2 Permitting ..................................................................................................................................49

5.4.3 2009 Activities............................................................................................................................50

5.5 Surface Water Protection (Stormwater and Erosion Control)..........................................................50

5.5.1 Program Management...............................................................................................................50

5.5.2 Permitting ..................................................................................................................................51

5.5.3 2009 Activities............................................................................................................................51

5.6 Waste Management .........................................................................................................................51

5.6.1 Program Management...............................................................................................................51

5.6.2 Permitting ..................................................................................................................................52

5.6.3 2009 Activities............................................................................................................................52

5.7 Storage Tanks (Underground and Aboveground).............................................................................52

5.7.1 Program Management...............................................................................................................52

5.7.2 Permitting ..................................................................................................................................53

5.7.3 2009 Activities............................................................................................................................53

5.8 Hazardous Materials Management ..................................................................................................53

5.8.1 Program Management...............................................................................................................53

5.8.2 Permitting ..................................................................................................................................55

5.8.3 2009 Activities............................................................................................................................55

5.9 Pollution Prevention and Sustainability............................................................................................55

5.9.1 Program Management...............................................................................................................55
NREL Environmental Performance Report- 2009 Page viii

5.9.2 Permitting ..................................................................................................................................56

5.9.3 2009 Activities...........................................................................................................................56

5.10 Vegetation Management................................................................................................................56

5.10.1 Program Management.............................................................................................................56

5.10.2 Permitting ................................................................................................................................57

5.10.3 2009 Activities..........................................................................................................................58

5.11 Wildlife............................................................................................................................................58

5.11.1 Program Management.............................................................................................................58

5.11.2 NWTC Site ................................................................................................................................58

5.11.3 STM Site ...................................................................................................................................59

5.11.4 Permitting ................................................................................................................................60

5.11.5 2009 Activities..........................................................................................................................60

5.12 Endangered Species/Species of Concern........................................................................................62

5.12.1 Program Management.............................................................................................................62

5.12.2 Permitting ................................................................................................................................63

5.12.3 2009 Activities..........................................................................................................................63

5.13 Wetlands/Floodplains.....................................................................................................................64

5.14 Cultural Resources..........................................................................................................................65

5.14.1 Program Management.............................................................................................................65

5.14.2 Permitting and Requirements..................................................................................................67

5.14.3 2009 Activities..........................................................................................................................67

5.15 National Environmental Policy Act (NEPA) .....................................................................................67

5.15.1 Program Management.............................................................................................................67

5.15.2 Permitting ................................................................................................................................67

5.15.3 2009 Activities..........................................................................................................................67

5.16 Radiological Program ......................................................................................................................68

5.16.1 Program Management.............................................................................................................68

5.16.2 Permitting ................................................................................................................................69

5.16.3 2009 Activities.........................................................................................................................69

6 Conservation Easement Lands............................................................................................................70

6.1 2009 Property Assessment ...............................................................................................................71

7 Contacts for Feedback or More Information......................................................................................72
NREL Environmental Performance Report- 2009 Page ix

8 References ..........................................................................................................................................73

9 Appendices..........................................................................................................................................75
NREL Environmental Performance Report- 2009 Page 1

1 Introduction

The National Renewable Energy Laboratory (NREL) is the nation's premier laboratory for renewable 

energy research and development and a leading laboratory for energy efficiency research, with 

programs in wind energy, solar energy, plant and waste-derived fuels and chemicals, energy 

efficiency in buildings, geothermal energy, advanced vehicle design, hydrogen infrastructure, and 

fuel cells. Established in 1974, NREL began operating in 1977 as the Solar Energy Research Institute 

(SERI). It was designated a U.S. Department of Energy (DOE) national laboratory in September 

1991 as the National Renewable Energy Laboratory. NREL conducts research primarily for DOE’s 

Office of Energy Efficiency and Renewable Energy. In October 2008, the management and operating 

contract for NREL was awarded to the Alliance for Sustainable Energy, LLC, a partnership between 

the Midwest Research Institute (MRI) and the Battelle Memorial Institute. The new operating 

contract has a 5-year duration and is overseen by the Department of Energy’s Golden Office (DOEGO).

1.1 Purpose 

This report presents a summary of NREL’s environmental protection programs and activities for 

2009. It is organized according to the different environmental media (e.g., air, waste, ground water, 

etc.), and includes a brief summary of how the program is managed in that area, any permitting or 

notification efforts that have been completed during the reporting period or are ongoing, and 

activities that have occurred during the reporting period in that environmental area. A description of 

the environmental condition and features of NREL’s sites is also included to provide a basis for the 

program overview. 

This report is organized to present many of the elements of the Global Reporting Initiative 

Sustainability Reporting Guidelines. It also incorporates DOE’s most recent guidelines for the 

Annual Site Environmental Report, as required by DOE Orders 231.1A, Environment, Health and 

Safety Reporting and 5400.5, Radiation Protection of the Public and Environment. 

1.2 Background 

NREL’s mission and strategy are focused on advancing the U.S. Department of Energy’s and our 

nation’s energy goals. This focus is captured in the mission statement: 

NREL develops renewable energy and energy efficiency technologies and practices, 

advances related science and engineering, and transfers knowledge and innovations to 

address the nation’s energy and environmental goals. 

NREL fulfills its mission through four key areas of competency, which allows for the development

and advancement of renewable energy and energy efficiency technologies. NREL's R&D 

competencies are:

Renewable electricity conversion and delivery systems 

Renewable fuels formulation and delivery 

Efficient and integrated energy systems 

Strategic energy analysis 
NREL Environmental Performance Report- 2009 Page 2

There are thirteen areas where NREL applies these competencies:

Advanced Vehicles and Fuels: In this area, NREL assists industry in introducing advanced, lowemission, economically competitive vehicles and fuels to the marketplace.

Basic Science: Fundamental research is conducted in the sciences that underlie NREL’s renewable 

energy and energy efficient technologies. 

Biomass: NREL currently has major programs in biomass-derived fuels (biofuels) and biomassderived electricity (biopower), and projects in biomass-derived chemicals and materials. 

Buildings: NREL increases the use of energy efficiency technologies and expands the use of 

renewable energy technologies in the building sector by working to develop new, cost-effective, 

environmentally acceptable building equipment and envelope systems. 

Computational Sciences: This area includes basic and applied research using high-performance 

computing and applied mathematics.

Concentrating Solar Power: NREL collaborates with industry to further the research and 

development of concentrating solar power (CSP) plant and solar thermal technologies.

Electrical Infrastructure Systems: NREL’s efforts in this area are focused on renewable energy 

integration, distributed energy testing and certification, interconnection and control technology, and 

energy management and grid support.

Energy Analysis: Research at NREL includes energy analysis for various programs and initiatives. 

These analyses are used to inform decisions as energy-efficient and renewable energy technologies 

advance from concept to commercial application.

Geothermal: NREL works in partnership with industry, academia, and other research laboratories 

to research, develop, and demonstrate technologies to advance the use of geothermal energy as a 

clean, renewable, domestic power source for the United States.

Hydrogen and Fuel Cells: NREL serves as a leader in renewable hydrogen production technologies. 

NREL also leads in the development of codes, standards, and advanced storage and sensors. Basic 

and applied research and material development using biology, physics, and chemistry enable and 

support the development of hydrogen production, storage, and end-use systems. 

Photovoltaics: Photovoltaics (PV) enable the direct conversion of sunlight to electricity using solidstate materials. The National Center for Photovoltaics develops and deploys PV technology for the 

generation of electric power. 

Renewable Resource Maps and Data: NREL provides high-quality renewable energy resource data 

for U. S. and international locations. NREL’s Renewable Resource Data Center is the world’s 

largest free collection of renewable energy resource data.
NREL Environmental Performance Report- 2009 Page 3

Wind: Through the National Wind Technology Center (NWTC), NREL develops, improves, and 

demonstrates the viability of wind technology for electricity generation and facilitates its utilization 

throughout the world.

1.3 Site and Facility Description 

NREL facilities occupy five separate locations in Jefferson County, Colorado, near the city of 

Denver, and one within the boundaries of the City and County of Denver. The five facilities in 

Jefferson County include the Denver West Office Park (DWOP), Golden Hill (GH),the South Table 

Mountain site (STM), the Joyce Street Facility (JSF), and the NWTC. The Renewable Fuels and 

Lubricants Research Laboratory (ReFUEL) is located within the city limits of Denver. The DWOP 

and STM sites are approximately two miles (3.2 km) east of Golden and 12 miles (19.3 km) west of 

central Denver. The NWTC is located near the intersection of Highways 93 and 128, between 

Boulder and Golden, and is approximately 15 miles (24.2 km) north of the STM site. The JSF is 

located at 6800 Joyce Street, about 5.5 miles (8.9 km) north of the DWOP and STM sites. The 

ReFUEL facility is located with the Regional Transportation District (RTD) District Shops and 

Operation Center (DSOC) at 1900 31st Street, Denver, about 12 miles east of the STM and DWOP 

sites. Figure 1 illustrates the locations of the STM, DWOP, NWTC, and JSF sites on a regional map. 

The location of the ReFUEL facility is shown in Figure 2. Figure 3 provides a more detailed map of 

the STM site, and Figure 4 provides detail for the NWTC site. 

The STM and NWTC sites are the two main sites where research operations are conducted and will 

be addressed separately in the discussion of environmental features. The DWOP is leased space used 

primarily for administrative functions and limited research activities. The JSF is also a leased space 

that is currently used for storage. The ReFUEL facility is a leased facility that consists of a small 

shop complex housed within the RTD/DSOC facility. NREL performs engine-testing activities 

pertaining to fuels and lubricants at the site.

Recent changes to the NREL South Table Mountain campus include a new heating plant and a 

photovoltaic array and the on-going construction of the new Research Support Facility. The 

Renewable Fuels Heat Plant (RFHP) was constructed between the Field Test Laboratory Building 

and the Solar Energy Research Facility in 2008 to provide heat to STM campus buildings. Using 

wood chips from a variety of sources along Colorado's Front Range, the RFHP provides hot water 

through underground pipes to heat all of NREL's facilities on the STM site. The RFHP has an 

estimated output of 29 billion BTUs per year; however, it saves more than 40 billion BTUs of natural 

gas due to conversion efficiencies. The 2009 – 2010 heating season will be the first full season of 

operation for the RFHP.

Construction of the Research Support Facility (RSF) continued throughout CY2009, with a 

scheduled completion date of June 2010. The RSF is a 222,000 square foot building which will house 

800 employees and is so energy efficient that it will only consume as much energy as can be 

generated by renewable power on or near the building. It is being designed to meet the stringent 

standards of the U. S. Green Building Council’s Leadership in Energy and Environmental Design 

(LEED) program to achieve a Platinum rating. Supplementing the ongoing construction of the RSF in 

2009 was the South Table Mountain (STM) Infrastructure Project, which extends the current utility 

infrastructure to support new facilities and the buildout of the STM.

In addition to the RSF, construction activities in 2009 also included the installation of an 8 acre 

photovoltaic system at the National Wind Technology Center and the beginning of construction on 
NREL Environmental Performance Report- 2009 Page 4

an addition to the Alternative Fuels User Facility (AFUF), the Integrated Biorefinery Research 

Facility (IBRF). 

Figure 1. Regional map showing NREL locations in Jefferson County, CO

National Wind 

Technology Center

Joyce Street 

Facility
NREL Environmental Performance Report- 2009 Page 5

Figure 2. ReFUEL Facility location map, located in Denver County, CO

NREL

ReFUEL

Facility

I-25

I-70
NREL Environmental Performance Report, 2009 Page 6

Figure 3. STM site detail
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Figure 3. NWTC site detail
NREL Environmental Performance Report- 2009 Page 8

Figure 5. Research Support Facility

Figure 6. South Table Mountain Mesa Top
NREL Environmental Performance Report- 2009 Page 9

Figure 7. South Table Mountain Campus

Figure 8. Denver West Office Park
NREL Environmental Performance Report- 2009 Page 10

1.3.1 South Table Mountain Site 

1.3.1.1 Geology, Soils, and Hydrogeology 

The South Table Mountain (STM) site is a roughly triangular parcel of land occupying portions of 

the top, sides, and lower south-facing slopes of STM. STM is composed of sedimentary rocks below 

a basalt lava cap, which is quite resistant to erosion. The STM feature is a mesa that stands about 150 

meters above the adjacent lowlands. The mesa was formed as weak sedimentary rocks surrounding 

the lava were eroded away, leaving the lava-capped mesa in relief. Below the lava caprock, the 

sedimentary rocks are part of the Denver Formation that consists of layers and lenses of claystone, 

sandstone, and conglomerate. Sedimentary rocks of the Arapahoe Formation underlie the Denver 

Formation. 

Both the Arapahoe and Denver Formations are considered to be aquifers in portions of the Denver 

Basin. The Denver Formation underlies the areas on which most NREL construction has taken place. 

Groundwater on the STM site occurs primarily in the weathered and fractured silts and sands of the 

Denver Formation. There may also be some groundwater in the form of perched aquifers below the 

basaltic lava cap on the STM, and within the materials above the Denver Formation, which are 

largely the result of stream deposits. Groundwater flow on the site is in a southeasterly direction. 

The soil covering the top of the STM is lavina loam. Loam is composed of a mixture of clay, sand, 

silt, and organic matter. The loam on the mesa top is a shallow, well-drained clayey soil. Soil on the 

upper side slopes of the STM is also a loam consisting of extremely stony soils with significant 

amounts of clay. Much of the remainder of the site, including the area designated for major 

development, has a deep, well-drained soil referred to as Denver clay loam. It consists of clayey 

material containing some calcium carbonate. There are also two smaller soil areas on the 

southwestern portion of the site, both of similar character to other site soils—cobbly clay loam and 

very stony clay loam. 

1.3.1.2 Surface Water 

About 90% of the surface drainage off the site, both from the mesa top and across the lower portions 

of the site, is in the southerly direction toward Lena Gulch (a tributary of Clear Creek). Surface water 

from two drainage ways on the easternmost portion of the site ultimately flows into Lena Gulch. 

There is no permanent stream flow on the STM site. Only occasional flow derived from extended 

periods of precipitation, usually during the late winter and early spring, is found in the drainage 

channels, with seasonal springs evident along some of the mesa slopes. There is one seep on the mesa 

top that is often active throughout much of the year, but the water infiltrates and evaporates quickly 

during the dry season. 

1.3.1.3 Vegetation 

Two primary vegetation types are present on the STM site: grasslands and shrublands. The most 

common plant communities on the STM site are mixed grasslands, composing more than 80% of the 

vegetation on the site. These communities are generally dominated by short- and mid-grass species. 

Two primary upland shrub communities occur on the STM site: mountain mahogany shrublands, 

found on the shallow soils of the mesa, and upland shrublands, occurring in drainages lacking active 

channels as well as drainages with associated wetlands. Field surveys have identified limited 

wetland/riparian areas along drainages. The wetland communities identified on the STM site are a 

minor component of the total vegetation cover, accounting for less than 1% of the vegetation over an 
NREL Environmental Performance Report- 2009 Page 11

area of less than 0.3 hectares (0.75 acres). Riparian shrub communities also occur adjacent to the 

emergent wetlands. 

1.3.1.4 Wildlife 

A wildlife survey was conducted on the site during 1986 and 1987, and additional surveys were done 

in 1999 over the conservation easement property. A survey to update the existing data began in 2004 

and was completed in 2005 (see Section 5.11 for more detail). Mammals seen using the site during 

the surveys include mule deer, coyotes, gray foxes, red foxes, raccoons, long tailed weasels, striped 

skunks, spotted skunks, badgers, bobcats, mountain lions, rabbits, and yellow-bellied marmots.

Seventeen species of birds have been observed on the STM site, along with two species of raptors: 

American kestrels and two nesting pairs of red-tailed hawks. Amphibian species and snakes are 

known to inhabit the area as well. 

1.3.1.5 Land Use 

The STM site is a 327-acre area predominantly bordered by open grassland zoned for recreation and 

light-commercial activity. Portions of the community of Pleasant View are located immediately to 

the south and west of the western portions of the STM site. Pleasant View has constructed a 

recreational park immediately south of the STM site. Offices, shops, and a tree nursery owned by the 

Colorado State Forest Service are located at the far western edge. Undeveloped state land and a 

Colorado State Highway Patrol pursuit driver-training track are located along the northwestern 

boundary of the STM site on top of the mesa. Jefferson County open space wraps around the 

northern and the eastern edge of the site. Portions of the DWOP and apartment homes lie to the east. 

More than half of the STM site (177 acres) has been set aside in a conservation easement. No 

development is allowed on that land, with the exception of some existing utility easements and 

recreational trails to be established by Jefferson County Open Space. Trail development planned for 

implementation in phases by the County began in 2004 (see Section 6.0 for more detail).

1.3.2 National Wind Technology Center 

1.3.2.1 Geology, Soils, and Hydrogeology 

The National Wind Technology Center (NWTC) site is located on a plain formed by stream deposits. 

The uppermost geological layer beneath the site is known as the Rocky Flats Alluvium (RFA). It is 

composed of cobbles, coarse gravel, sand, and gravelly clay. Below the RFA are the Laramie 

Formation, Fox Hills Sandstone, and Pierre Shale. These rock formations consist primarily of 

claystones with some siltstones. Unconfined groundwater flow occurs in the RFA toward the

east/southeast, and small perched zones are common. Groundwater occurs as confined aquifers in the 

deeper bedrock formations (EG&G Rocky Flats, Inc. 1992). 

The NWTC has a strongly developed soil defined as a very cobbly, sandy loam. The soil is 

characterized by a large amount of cobble and gravel in the soil volume, and subsoil dominated by 

clay (USDA 1995). 

1.3.2.2 Surface Water 

The area surrounding the NWTC site is drained by five streams: Rock Creek, North Walnut Creek, 

South Walnut Creek, Woman Creek, and Coal Creek. Rock Creek flows eastward and is located 

southeast of the NWTC. North Walnut Creek and South Walnut Creek flow eastward into the Great 
NREL Environmental Performance Report- 2009 Page 12

Western Reservoir. Woman Creek drains eastward into Standley Lake. Coal Creek flows in a 

northeasterly direction across the City of Boulder open space north of the NWTC. 

The majority of the NWTC drains into a tributary to Rock Creek. Some of the northern portions of 

the site drain into Coal Creek or its tributaries. 

1.3.2.3 Vegetation 

The NWTC is located in the transition area between the Great Plains and the Rocky Mountains 

(Plantae Consulting Services 2000). This location results in a flora that contains elements from both 

mountain and prairie ecosystems, and associations that represent residual tall grass prairie, shortgrass plains, ponderosa pine woodland, and foothill ravine flora (Plantae Consulting Services 2000). 

A vegetation study conducted between August 1999 and August 2000 identified 271 vascular plant 

species and defined five major habitat types on the NWTC site, including: seasonal wetlands/or 

ephemeral hydric soils, woodlands, shrublands, mixed grasslands, and disturbed areas. 

Along the northwestern ridge is a Ponderosa Pine woodland area. Vegetation found in this area 

includes woody species with an understory of grasses, forbs, and shrubs. 

1.3.2.4 Wildlife 

Prior to 1975, livestock heavily grazed the NWTC site, damaging a majority of the native vegetation. 

A wildlife survey was conducted in 1992 for the entire Rocky Flats Plant and buffer zone area, 

including the NWTC site. Signs or tracks of bears and mountain lions were identified. Other 

mammals known to feed at the site are mule deer, coyotes, desert cottontail rabbits, white-tailed 

jackrabbits, black-tailed jackrabbits, deer mice, prairie voles, and thirteen-lined ground squirrels. 

Approximately 20 different species of birds were sighted at or near the site. Raptor (birds of prey) 

surveys were conducted at the NWTC in 1994 and 1995, and identified seven raptor species on or in 

the vicinity of the site. An avian survey was also conducted in 2001 to 2002 (see Section 5.11). 

Although seldom seen, rattlesnakes, bull snakes, racers, and several other reptilian and amphibian 

species are known to occupy the area. 

1.3.2.5 Land Use 

The NWTC facility occupies a 305-acre area surrounded largely by open space and grazing land. The 

former Rocky Flats Environmental Technology Site land borders the NWTC to the southeast, and a 

sand and gravel mining and processing operation is located along the southern and western 

boundaries of the site. A blasting company also has a small installation along the western site 

boundary. 

1.3.3 Denver West Office Park/Golden Hill

The Denver West Office Park (DWOP) is a relatively flat, landscaped office complex occupied by a 

number of four-story buildings, parking lots, and common areas. NREL-leased facilities at the 

DWOP are located approximately in the geographic center of the development along West Colfax

Ave. The Golden Hill facility is leased office space on Colfax Ave. east of the DWOP location. The 

DWOP is bordered on the south by commercial areas (West Colfax strip), on the west by the Pleasant 

View residential area, Camp George West facility, and the STM site. The DWOP is within the City 

of Lakewood.
NREL Environmental Performance Report- 2009 Page 13

1.3.4 Joyce Street Facility 

The Joyce Street Facility (JSF) is located in a commercial area surrounded by agricultural land, 

residential neighborhoods, and small businesses. It is currently used by NREL primarily as 

warehouse space only. Support activities and limited dry lab research activities are currently 

conducted at the facility, and there are no staff offices at JSF. 

1.3.5 Renewable Fuels and Lubricants Research Laboratory 

The Renewable Fuels and Lubricants Research Laboratory (ReFUEL) is used for research, testing, 

and support activities related to advanced fuels, engines, and vehicles to objectively evaluate 

performance, emissions, and energy efficiency impacts. The laboratory is also used to evaluate and 

develop heavy hybrid electric vehicles. 

The ReFUEL is a small shop complex housed within the RTD/DSOC facility. The RTD/DSOC 

facility occupies approximately 22 acres of land and serves as the primary maintenance facility for 

RTD’s bus and light rail train systems. The area around the RTD/DSOC facility consists of 

commercial and light industrial development. 

The site lies on relatively flat terrain with a slight gradient to the northwest. The general area is 

highly developed with concentrated industrial and commercial activities. Very little natural vegetated 

habitat exists on site or in the immediate vicinity. There are trees and shrubs lining the South Platte 

River adjacent to the site’s south, east, and northeast borders. 

1.4 Site Environmental Conditions/Features 

Photos for each site documenting the site features and development are included at the end of this 

section. Figures 5, 6, 7, and 8 show the STM and DWOP sites, and Figures 9 and 10 provide images 

of the NWTC site. The views on the STM site also illustrate the conservation easement property and 

the Camp George West property acquired in 1999. 

1.4.1 Climate 

The climate for the geographic region of NREL operations is classified as semi-arid, typified by 

limited precipitation, low relative humidity, abundant sunshine, and large daily and seasonal 

temperature variations. 

The area experiences moderate precipitation, with an average annual rainfall of less than 50 cm (20 

inches). Almost half of the annual precipitation occurs from March to June. Summer showers 

contribute 33% of the annual precipitation total. Precipitation begins to decrease significantly in the 

fall, and reaches the minimum during winter. Winter is the driest season, contributing less than 10% 

of the annual precipitation, primarily in the form of snowfall. 

Spring is a season of unstable air masses with strong winds along the foothills and the Front Range. 

The highest average snowfall occurs in March, and the STM site can generally expect to experience 

at least one heavy snowstorm with totals exceeding 15 to 25 cm (6 to 10 inches). 

The solar radiation (sunlight energy) of the region is excellent for outdoor research and testing of 

solar energy conversion devices and systems. Sunshine is abundant throughout the year and 

remarkably consistent from month to month, season to season.
NREL Environmental Performance Report- 2009 Page 14

2 Compliance Summary 

2.1 Laws and Regulations

2.1.1 Air Quality Protection

The Colorado Department of Public Health and Environment (CDPHE) administers the Clean Air 

Act implementing regulations for all point sources (facilities or other types of operations) in 

Colorado, under authority delegated by the U.S. Environmental Protection Agency (EPA). NREL is 

not a major source for air pollutants, but does hold two site-wide permits for particulate air emissions 

from construction, one air emissions permit for a pilot-scale research project, and one air permit for 

the operation of the RFHP, a woodwaste-fired heating plant. Detailed information about NREL’s air 

quality protection program is provided in Section 5.1. 

National Emissions Standards for Hazardous Air Pollutants (NESHAP) requirements specific to 

radiological emissions from DOE facilities are regulated by the EPA. Details are provided in Section 

5.16.

In 2009, NREL filed a Malfunction Event Report with the Air Quality Control Division of CDPHE.

On March 19, wet fuel introduced into the RFHP during start up resulted in a 30 minute period 

during which the opacity of the stack emissions was estimated at 60%. This exceeded the allowable 

level of 30% opacity during start up for no more than 6 minutes. The report also described the 

corrective actions taken by the operators to prevent such events in the future.

2.1.2 Drinking Water Quality Protection 

Drinking water quality is regulated for all public water suppliers in Colorado by the CDPHE, under 

authority delegated by the EPA. NREL purchases water that is delivered by truck to the NWTC, and 

holds a public water supply identification number to operate the NWTC distribution system. NREL 

has been conducting increased monitoring since the fourth quarter of 2006 for disinfection 

byproducts. Detailed information about system performance is provided in Section 5.2. 

In 2009, NREL had no drinking water compliance issues. 

2.1.3 Groundwater Quality Protection 

Colorado groundwater quality standards are established by the CDPHE. Permits for groundwater 

wells are issued by the state engineer’s office. NREL has no known groundwater contamination and 

has obtained drilling permits for all of its monitoring wells. Detailed information about NREL’s 

groundwater program is provided in Section 5.3. 

In 2009, NREL had no groundwater compliance issues. 

2.1.4 Wastewater 

Wastewater from the majority of the STM site and the Denver West Office Park is discharged into 

the Pleasant View Water and Sanitation District’s (Pleasant View) collection system, and flows to the 

Metropolitan Wastewater Reclamation District (Metro) treatment plant. The federal Clean Water Act 

and Colorado Water Quality Control Act regulations are administered at NREL’s STM and DWOP 

via Pleasant View and Metro pretreatment program requirements. NREL’s wastewater discharge 

policy is in conformance with Metro’s discharge requirements. 
NREL Environmental Performance Report- 2009 Page 15

Wastewater at the NWTC site flows into two individual sewage disposal systems (septic and leach 

fields). These are regulated by CDPHE; inspection and permit issuance have been delegated by 

CDPHE to the Jefferson County Department of Health and Environment. There is also one individual 

sewage disposal system at the Solar Radiation Research Laboratory (SRRL) on the mesa top at the 

STM site. As is the case with NWTC septic systems, the mesa top system regulations are 

administered by Jefferson County. Additional detail about NREL’s wastewater discharge program 

can be found in Section 5.4. 

In 2009, NREL had no wastewater compliance issues. 

2.1.5 Surface Water Quality Protection 

Stormwater discharge regulations are administered by the EPA at federal sites in Colorado. As a 

result, NREL falls under the EPA Construction General Permit (CGP) program for the STM and 

NWTC sites for stormwater discharge from construction activities. Permit coverage for individual 

NREL activities is obtained when permit thresholds are triggered. 

At the STM, a Notice of Intent (NOI) was filed with the EPA in 2009 for the construction of the 

Integrated Bio-Refinery Facility (IBRF) and the STM Infrastructure project. These activities 

continued through 2009.

At the NWTC, a NOI was filed with EPA in 2009 for the Sun Edison 1 megawatt photovoltaic array 

field. This project occupies about 8 acres in the western portion of the NWTC.

In 2009, NREL had no surface water compliance issues. 

2.1.6 Waste Management 

The Resource Conservation and Recovery Act (RCRA) established federal authority over hazardous 

waste. In Colorado, the CDPHE administers hazardous waste regulations under authority delegated 

by the EPA. NREL holds five EPA generator identification numbers for each of its sites. NREL’s 

waste management program is outlined in Section 5.6. Pollution prevention efforts at NREL are 

described in Section 5.9. 

In 2009, NREL had no waste management compliance issues. 

2.1.7 Storage Tanks 

NREL has no underground storage tanks containing hazardous materials. Aboveground storage tanks 

(ASTs) that are larger than 660 gallons are regulated in Colorado by the Colorado Department of 

Labor and Employment’s Oil Inspection Section. NREL has two tanks larger than 660 gallons on the 

STM site that are registered with the Colorado Department of Labor and Employment. Details about 

NREL’s AST program are provided in Section 5.7. 

No spills or releases from NREL’s ASTs occurred during 2009.

2.1.8 Threatened and Endangered Species/Species of Concern

Wildlife is protected by a number of federal laws, including (but not limited to) the Endangered 

Species Act, the Migratory Bird Treaty Act, and the Golden and Bald Eagle Protection Act. The 

Endangered Species Act also protects threatened and endangered plant species. State laws designate 
NREL Environmental Performance Report- 2009 Page 16

and protect rare or unique plants and animals as well. No threatened or endangered species or species 

of concern have been documented on NREL’s sites. Details of NREL’s wildlife and vegetation 

surveys are provided in Sections 5.10 and 5.11. 

In 2009, NREL had no compliance issues regarding wildlife. 

2.1.9 EPCRA Compliance and Prevention of Toxic Releases 

Executive Order (EO) 13423, Strengthening Federal Environmental, Energy, and Transportation 

Management, and DOE Order 450.1A, Environmental Protection Program, outline requirements for 

Superfund Amendments and Reauthorization Act (SARA) Title III, Emergency Planning and 

Community Right-to-Know Act (EPCRA) compliance, and Toxic Release Inventory reductions for 

DOE facilities. NREL maintains hazardous materials permits with West Metro Fire Rescue (West 

Metro) and provides chemical inventory information to West Metro for the STM site and Building 16 

in the DWOP. NREL’s ReFUEL facility holds a Hazardous Materials Permit issued by the Denver 

Fire Department.

Federal facilities that use, produce, or store extremely hazardous substances in quantities above 

specific release thresholds are required to report on their inventory to various federal, state, and local 

emergency planning authorities, as required by EPCRA provisions in Title III of the Superfund 

Amendments and Reauthorization Act (SARA). A summary of the EPCRA requirements and the 

applicability to NREL is presented in the table below.

In 2009, NREL facilities had no releases exceeding the reportable quantity (RQ) of any material 

reportable under EPCRA. As a research and development laboratory, NREL does not manufacture or 

process any materials on the SARA Section 313 list in excess of the applicable threshold planning 

quantity. And during 2009, the laboratory did not otherwise use any materials on the SARA Section 

313 list in quantities exceeding the applicable threshold planning quantity. NREL’s compliance with 

EPCRA requirements is detailed in Section 5.8. 

Status of EPCRA Reporting

EPCRA Section Description of Reporting Status

EPCRA Sec. 302-303 Planning Notification Reporting threshold not met*

EPCRA Sec. 304 EHS Release Notification Reporting threshold not met

EPCRA Sec. 311 -312 MSDS/Chemical Inventory Reporting threshold not met

EPCRA Sec. 313 TRI Reporting Reporting threshold not met

* NREL maintains hazardous materials permits with West Metro Fire Rescue (West Metro) and reports chemical inventory 

information to West Metro for the STM site and Building 16 in the DWOP. NREL’s ReFUEL facility holds a Hazardous 

Materials Permit issued by the Denver Fire Department which requires an annual report of the chemical inventory.

NREL maintains an Emergency Management Policy (8-4) and supporting lab-level programs for 

credible on-site emergencies. In 2009, the NREL Emergency Management Manual was updated to 

include a complete description of the lab’s activities that demonstrate compliance with all applicable 

emergency requirements of the Colorado Hazardous Waste Regulations. Hazardous material releases 

are specifically identified as a credible emergency, and response procedures are in place. These 

procedures are routinely practiced by internal response groups and with external emergency response 
NREL Environmental Performance Report- 2009 Page 17

agencies. In 2009, the NREL Emergency Response Team (ERT) and West Metro worked together on 

an actual event at the Solar Energy Research Facility, described in Section 3.4.1.

2.1.10 Cultural Resources Protection 

Various laws, including but not limited to, the National Historic Preservation Act and the Native 

American Graves Protection and Repatriation Act, protect cultural resources. NREL has two sites 

listed on the National Register of Historic Places (National Register) on its STM site. There are no 

known eligible sites at the NWTC (see Section 5.14). 

In 2009, NREL consulted with the State Historic Preservation Officer (SHPO) during the 

Environmental Assessment for the proposed construction activities on STM, including the STM 

Infrastructure, Energy Systems Integration Facility (ESIF), and the second full service access road. 

There were no comments on the Infrastructure or ESIF projects, but the SHPO reserved comment on 

the access road until a final determination is made on its alignment. 

2.1.11 Other

During the course of operating a major national laboratory, events occur which may have an impact 

on the environment. The NREL site experienced one incident in 2009 that had minor environmental 

impacts but initiated several operational changes at the lab.

Hexamethyldisilthiane Spill

On May 1, 2009, a researcher in the Solar Energy Research Facility (SERF) broke a vial of 

hexamethyldisilthiane releasing the contents into a laboratory. While the work had been conducted in 

a hood, the vial fell out of the hood resulting in a release of the chemical into the ventilation system 

of the laboratory and, eventually, in both the SERF and the adjacent Science and Technology Facility

(S&TF). The event was attributed to the researcher using an inappropriate tool to open the glass vial, 

deviating from the approved operating procedure. During the evaluation following the incident, 

laboratory practices were reviewed and revised to prevent such events in the future and to provide 

accurate safety information in a timely manner.

Hexamethyldisilthiane is extremely odiferous, with the potential for harmful health effects, 

prompting emergency response personnel to recommend evacuating both buildings. Both internal 

and external response organizations were present for this incident and worked together to effectively 

control the situation. There was no release to the environment and no compliance issues as a result of 

this event. However, NREL did make several operational changes in response to this event, 

including additional worker training, enhanced mentorship amongst researchers, and changes to the 

availability of emergency response information.

2.2 DOE Order 450.1A, Environmental Protection Program 

DOE Order 450.1 required sites to implement an Environmental Management System (EMS) by 

integrating them with the site’s Integrated Safety Management System. Sites were required to have 

an EMS in place by December 31, 2005. The revised Order 450.1A requires that EMSs now be 

structured according to International Organization for Standardization (ISO)14001 requirements by 

June 2009. NREL’s implementation of its EMS is described in Section 4.0 of this report. 
NREL Environmental Performance Report- 2009 Page 18

2.3 Executive Orders 

There are a number of Executive Orders (EO) related to the environment that direct DOE activities 

and subsequent implementation at NREL. Those EOs that have the greatest affect on NREL 

planning, operations and management are discussed below.

2.3.1 Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic 

Performance

On October 5, 2009, the President signed EO 13514. This Order requires all federal agencies and 

departments to ―increase energy efficiency; measure, report, and reduce their greenhouse gas 

emissions from direct and indirect activities; conserve and protect water resource through efficiency, 

reuse, and stormwater management; eliminate waste, recycle, and prevent pollution; leverage agency 

acquisitions to foster markets for sustainable technologies and environmentally preferable materials, 

products, and services; design, construct, maintain, and operate high performance sustainable 

buildings in sustainable locations; strengthen the vitality and livability of the communities in which 

federal facilities are located; and inform federal employees about and involve them in the 

achievement of these goals.‖ NREL began implementation of this EO with an assessment of 

greenhouse gas emissions, and initiated plans for further activities in 2010.

2.3.2 Executive Order 13423, Strengthening Federal Environmental, Energy, and

Transportation Management

On January 24, 2007, the President signed EO 13423. This Order requires all federal agencies and 

departments to ―conduct their environmental, transportation, and energy-related activities under the 

law in support of their respective missions in an environmentally, economically, and fiscally sound, 

integrated, continuously improving, efficient, and sustainable manner‖ (72 FR 3919). One of the 

provisions of the EO is to reduce or eliminate the use of toxic materials. While NREL’s research 

needs cannot replace all toxic materials, efforts are made to reduce the quantities of toxic materials 

used at the laboratory. In 2009, chemical safety training materials were enhanced to encourage 

researchers to find less toxic alternatives wherever possible.

2.3.3 Executive Order 11988, Floodplains Management 

EO 11988 was implemented in support of the National Environmental Policy Act (NEPA), the 

National Flood Insurance Act of 1968, and the Flood Disaster Protection Act of 1973 to minimize the 

adverse impacts associated with development and modification of floodplains. According to maps 

generated by the Jefferson County Department of Highways and Transportation as part of its urban 

drainage studies, NREL's STM site does not contain any floodplains, and no floodplains have been 

identified at the NWTC. As a best management practice (BMP), however, all construction activities 

that may cross a drainage channel are designed to meet the 100-year flood control standards 

(designed to withstand the equivalent of a 100-year flood). Actions with the potential for 

environmental impact that are undertaken by NREL at subcontractor facilities are assessed for 

potential impacts on floodplains and wetlands at those sites through the use of an environmental 

checklist. 

2.3.4 Executive Order 11990, Wetlands Protection 

Under EO 11990, each federal agency must provide leadership and take action to minimize the 

destruction, loss, or degradation of wetlands, and to preserve and enhance the natural and beneficial 

values of wetlands. Limited wetland areas totaling less than 0.3 hectares (0.75 acres) occur on the 

STM site. These are narrow, linear wetlands supporting spikerush, baltic rush, sedges, bluegrass, 
NREL Environmental Performance Report- 2009 Page 19

hemlock, and field mint. Wetland areas at the NWTC are extremely limited in extent as well. These 

areas, along the site’s eastern boundary, total less than 0.4 hectares (1 acre).

In 2009, NREL had no compliance issues regarding environment-related EOs.

2.4 Permit Summary 

Appendix A contains a table summarizing NREL’s permits, registrations, and notifications.
NREL Environmental Performance Report- 2009 Page 20

3 NREL’s Positive Role in the Environment–Global and Local

As the nation’s premier resource for renewable energy information, research, and technology, NREL 

has a unique role in supporting the ―nation’s energy and environmental goals.‖ NREL has a positive 

environmental presence, both in the operation of the laboratory facilities and in the major impacts to 

global conditions by research done at NREL. Laboratory operations follow the NREL Environmental 

Management System (EMS), which is described in detail below and in the following chapter. NREL 

has earned its designation as an environmental leader by implementing an EMS, focusing 

environmental strategies through Sustainable NREL, and promoting sound environmental practices.

NREL’s mission is stated succinctly:

NREL develops renewable energy and energy efficiency technologies and practices, 

advances related science and engineering, and transfers knowledge and innovations to 

address the nation's energy and environmental goals.

Among the environmental imperatives addressed by NREL, carbon mitigation and land and water 

use are critical to the 21st century. A major change in the nation’s energy policy has spurred new 

research efforts at NREL to help address these issues. Renewable energy technologies will be critical 

to reversing the devastating effects of climate change and to moving forward to energy 

independence.

3.1 Energy Policy Updates

In 2008, there was a major shift in the energy policy of the United States with the passage of the 

Energy Independence and Security Act (EISA) which mandates significant changes in the energy 

production and use in the United States over the coming decades. The EISA has numerous provisions 

impacting vehicle fuel efficiency, including transportation electrification; funding for increased 

biofuel research and production; expanded research on solar, geothermal, marine, and hydrokinetic 

renewable technologies; support for research into carbon sequestration technologies; and provisions 

that will result in a modernization of the electrical transmission system known as Smart Grid. NREL 

has a critical role in helping the nation meet the legislative goals set in the EISA.

The Energy Information Agency (EIA), an independent arm of DOE, produces a summary document 

of energy use and projections called the Annual Energy Outlook (AEO). The 2008 AEO had been 

prepared with an early-release scenario in 2007, but was revised to account for the changes that the 

EISA would have on primary energy consumption and the emission of greenhouse gases (GHG) 

associated with the use of fossil fuels. The EIA projected a reduction of 5.3 quadrillion BTUs in total 

energy consumption from 2008 to 2030 as a result of EISA, and a 7% annual reduction in GHG 

emissions. The 2009 AEO did not specifically identify overall energy consumption reductions 

attributable to the EISA provisions, but it did predict strong growth in the use of biofuels of 3.3 

percent per year, compared to an overall growth in energy use of only 0.5 percent annually. The EIA 

did attribute the projected increase in the biofuels component of the fuel supply to the EISA.

By some estimates, the reduction of GHG emissions must be reduced by far greater amounts in the 

coming years, especially as the provisions of EO13514 (see Section 2) begin to be implemented.

Renewable energy is part of the solution to the reduction of GHG emissions as well as to help satisfy 

the nation’s growing appetite for energy in a sustainable manner. The EIA has summarized the 

sources of energy and the expenditures of energy in the United States (see Figure 13). Renewable 

energy is currently only a small contributor to the overall supply.
NREL Environmental Performance Report- 2009 Page 21

Increased research activities at NREL in response to changes in the national policy are only one 

example of the interface of policy and renewable energy. In 2009, NREL continued to make 

advances in renewable energy technologies that will contribute to the growth of this segment of the 

overall energy economy.

3.2 NREL Research Helping Meet Legislative Goals

Since its origination as the Solar Energy Research Institute (SERI), NREL has been involved in the 

fundamental development of solar energy technologies. As a research institution, NREL ranks 

second among all institutions (first among DOE laboratories) in the number of energy-related 

publications and has the unique distinction of having published the number one cited article in the 

energy field (M.A. Contreras, et al., Prog. Photovoltaics, 7: 311-6, 1999).

3.2.1 General Capabilities

With the addition of the National Wind Technology Center (NWTC), the Alternative Fuels Users 

Facility (AFUF), and a number of related facilities and organizations, NREL has increased the 

portfolio of research activities to include wind, biofuels, and energy efficiency technologies for 

residential, commercial, and industrial applications. Recently, NREL has increased the level of 

activity in energy delivery and storage, including energy transmission and distribution, alternative 

fuels, and hydrogen delivery and storage. For example, NREL has developed a wind-to-hydrogen 

project at the NWTC to demonstrate the technologies of converting wind and solar energy into 

hydrogen through the electrolysis of water. In addition, the Hydrogen Test Facility began operations 

in 2007 where research is aimed at reducing the delivered costs of electrolytic hydrogen. Cost 

effective energy conversion and storage will greatly enhance the viability of renewable energy 

technologies, particularly those where energy production is intermittent, such as wind and solar.

3.2.2 Biofuels

The EISA established rigorous goals for developing biofuel substitutes for petroleum-based fuels 

used for transportation (except ocean-going vessels). The Renewable Fuels Standard has now been 

expanded to require the annual production of 36 billion gallons of renewable fuel in motor fuels by 

2022. Of that, 21 billion gallons must be from advanced biofuels, which is defined as biofuel 

produced from feedstocks other than corn starch. The EISA mandates that advanced biofuels include 

cellulosic fuels and biomass-derived diesel substitutes, and further, that these fuels have at least 50% 

less GHG emissions than petroleum fuels. NREL is well positioned to contribute to the development 

of biofuels technologies that will facilitate meeting these ambitious goals. The 2009 AEO predicts 

that the 2022 goal will not be met, but further predicts that the annual production of biofuels will 

significantly exceed the 36 billion gallon goal by 2030.

In 2009, NREL initiated work aimed at establishing cyanobacteria as a genetic model for solar 

biodiesel production. This work focuses on a specific strain of cyanobacteria that has the potential to 

store large amounts of triacylglycerols, the lipid feedstock for biodiesel production. In support of the 

biodiesel from algae research effort, the greenhouse at the Field Test Laboratory Building was 

renovated in 2009 to allow for the installation of algal growth chambers.

3.3 NREL–Research to Reverse Climate Change

The energy policy shift embodied by the EISA establishes rigorous goals to bring the nation to 

energy independence, but it also acknowledges the growing concern over climate change. The goals 

for reducing greenhouse gas emissions just begin to address the problem, however. In a 2007 report 

produced by the American Solar Energy Society entitled ―Tackling Climate Change in the U.S.‖, 
NREL Environmental Performance Report- 2009 Page 22

research indicates that GHG emissions in the United States must be reduced by the equivalent of 

1,100-1,300 million metric tons of carbon per year (MtC/yr) by 2030 to limit atmospheric carbon 

dioxide levels to between 450 and 500 ppm. The report goes on to say that this level of CO2

reduction can be achieved with a combination of energy efficiency improvements in the building, 

vehicles, and industrial sectors (57%), and renewable energy installations (43%).

Of the 43% reduction (516 MtC/yr) projected to be achieved through the deployment of renewable 

energy technologies, a majority of the GHG reduction would come from wind energy (181 MtC/yr). 

The additional reductions would be from concentrating solar power (CSP) (63 MtC/yr), photovoltaics 

(63 MtC/yr), biofuels (58 MtC/yr), biomass, (75 MtC/yr) and geothermal (83 MtC/yr). A recent 

survey of the growth of the first generation of these technologies from 2002 through 2007 shows that 

the installed capacity for wind generation has had the greatest increase. 

NREL is active in research in most of these areas, but particularly in wind, photovoltaics, and CSP. 

3.3.1 Wind

NREL continues to advance wind energy technologies at the National Wind Technology Center. In 

2009, the installed wind generation capacity at the NWTC was increased significantly. In August, the 

installation of a 1.5 megawatt General Electric wind turbine was completed, followed by the 

installation of a 2.3 megawatt Siemens unit. A number of research projects are associated with these 

two new installations, including a joint project to study the design and performance of wind turbine 

foundations.

3.3.2 Concentrating Solar Power

Concentrating solar power (CSP) technologies can be a major contributor to our nation's future need 

for new, clean sources of energy, particularly in the Western United States.

2009 will be remembered as a banner year for the CSP program when NREL won two R&D 100 

awards. The first was for a high-efficiency parabolic trough collector for utility-scale solar thermal 

power plants. The new trough design uses a weatherproof, high-reflectance polymer film which 

solves a number of problems that existing trough designs present. The NREL CSP program also won 

a 2009 R&D 100 award for the Ultra-Accelerated Weathering System, which allows researchers to 

see the degradation caused by long term weathering without having to wait years or decades for 

results.

3.3.3 Photovoltaics

The development of technology to capture solar energy is at the core of research conducted at NREL. 

The laboratory has won numerous awards for its innovative work in producing ever more efficient 

photovoltaic (PV) configurations, including two prestigious R&D 100 Awards in 2008, which 

received further recognition in 2009.

In 2009, Colorado Governor Bill Ritter recognized these accomplishments by presenting NREL with 

the Governor’s Award for Research Impact in Renewable Energy.

One of NREL's R&D 100 awards recognized the IMM Solar Cell, a breakthrough in solar cell design 

and performance. The ultra-light, highly efficient solar cell represents a new class of solar cells with 

clear advantages in performance, engineering design, operation, and cost. In this new method of 

development the cell is grown upside down, allowing for greater absorption and use of sunlight. By 
NREL Environmental Performance Report- 2009 Page 23

turning the conventional approach to cells literally on its head, the result is an ultra-light and flexible 

cell that converts solar energy with record efficiency. Having already set a pair of world records for 

solar conversion efficiency when it was nominated, the cell has just set a third world record with a 

solar conversion rate exceeding 40%.

The second R&D 100 award spotlights a new technology for manufacturing Hybrid CIGS—thin film 

PV employing layers of copper indium gallium diselenide. NREL, in partnership with HelioVolt, 

developed a method where hybrid CIGS cells are manufactured in layers by using ink-jet and 

ultrasonic technology to precisely apply metal-organic inks in separate layers directly into common 

building materials like metal and glass. This simple approach could integrate enough flexible PV film 

into windows, roofing, and other structural components to turn entire buildings into small, selfsustaining power plants.

3.4 NREL and the Community

NREL works with community organizations to implement laboratory sustainability practices and 

expand its clean energy technology research and development. Laboratory sustainability has been 

implemented through community meetings, laboratory tours, and community newsletters garnering 

community support for implementing goals. NREL's demonstration of clean work practices 

improves the local quality of life and sets an example for future community development.

Throughout 2009, NREL employees gave their time, money, and energy to help the community. 

They were backed by a commitment from the Alliance for Sustainable Energy, LLC to provide 

financial support that allowed NREL to work in community organizations, support local economic 

development efforts, and educate teachers, students, and consumers about renewable energy and 

energy efficiency.

NREL’s engagement with statewide business, government, and community leaders was at an all-time 

high this year. Economic and community outreach activities ranged from forums for the Metro 

Mayors’ Caucus to visits by Colorado’s Congressional Delegation and tours of NREL by economic 

development organizations, workforce boards, and municipal planning committees.

The Visitors Center is central to NREL’s interaction with the public. Not only is it the ―front door‖ to

the more than 18,000 visitors to the laboratory each year, it is an educational resource for consumers, 

teachers, and students. The addition of the Science on a Sphere exhibit attracted many new visitors 

with its 3-dimensional programs about energy’s impact on the world. Monthly consumer programs 

on hot new research topics and simple how-to instructional courses are regularly attended by 

hundreds of people.
NREL Environmental Performance Report- 2009 Page 24

4 Environmental Management System 

NREL's Environmental Management System (EMS) provides effective environmental stewardship of 

its federally-owned sites and minimizes the environmental impacts of the lab activities. The 

laboratory's EMS efforts protect and enhance the vegetation, wildlife, and natural resources of the lab 

sites; comply with environmental requirements; and encourage continuous improvement in 

environmental protection.

NREL’s Environmental Management System meets the requirements of the ISO14001 standard and 

was fully implemented prior to June 30, 2009, as required by DOE Order 450.1A, and was 

confirmed by DOE as meeting this requirement. In DOE's conformance letter dated June 26, 2009, 

DOE made this declaration based on the formal audit conducted on May 4-8, 2009 and that the 

appropriate NREL senior management and DOE Golden Field Office management have recognized 

and addressed the findings of the audit per the order (see section 4.1.3.2 for additional information).

For a full description of NREL’s EMS elements, please see NREL Environmental Management 

System Description available at http://www.nrel.gov/eshq/pdfs/43419.pdf .

Environmental protection is a priority at NREL, as demonstrated by the laboratory’s Environmental 

Protection Policy presented below.

NREL’s EMS implements the laboratory’s Environmental Protection Policy (below). It is a framework 

of policies, procedures, and programs integrated with normal management processes and combined 

with the environmentally sound daily work practices of the Environment, Health, and Safety (EHS) 

Office staff and personnel. Environmental protection must involve everyone at the lab to be effective. 

All activities conducted at NREL must comply with federal and state environmental laws and 

regulations, and DOE requirements.

As a DOE-owned facility, NREL is required by DOE Order 450.1A to implement its EMS as part of 

an ISM System. NREL’s EMS meets this requirement while also incorporating the elements of ISO 

14001, the international environmental management standard. In addition, the criteria of EO 13423, 

Strengthening Federal Environmental, Energy, and Transportation Management, are incorporated 

into the EMS. Policy 6-2: Environmental Protection, and supporting laboratory-level environmental 

programs and procedures that define the NREL EMS are coordinated and linked with Policy 2-1: 

Integrated Safety Management, Policy 2-7: Sustainable NREL, and the related supporting lab-level 

safety, health, and sustainability programs and procedures.
NREL Environmental Performance Report- 2009 Page 25

NREL Environmental Policy Statement

NREL exemplifies sustainability by maximizing efficient use of resources, minimizing waste and 

pollution, and serving as a positive force in economic, environmental, and community 

responsibility. To this end, NREL is committed to:

Economic Viability. Managing laboratory fiscal resources efficiently to meet applicable 

regulations and effectively accomplishing the laboratory's mission, taking sustainability into 

consideration.

Environmental Stewardship. NREL is committed to sound environmental management that 

serves as an example to others and supports the laboratory’s mission to protect natural resources 

through research, development, and deployment of renewable energy and energy efficiency 

technologies. To this end, NREL is committed to: 

Pollution Prevention. Incorporating pollution prevention practices in research and support 

activities

Continuous Improvement. Continuously improving the effectiveness of NREL’s 

environmental management system (EMS)

Campus. Managing the impact on the environment caused by the placement and general design 

of NREL structures; maintaining, protecting, and restoring natural and landscaped 

environments to sustain natural and native ecological systems, both on and adjacent to NREL 

campuses

Water. Reducing water consumption and managing water discharges from the site

Electricity/Natural Gas. Reducing energy use in building designs and operations, within 

available funds; using cost effective renewable energy sources for remaining energy needs; and 

purchasing power generated by renewable energy sources

Transportation. Reducing the impact of local NREL travel on the environment; reducing the 

use of fossil-based gasoline/diesel fuel for NREL onsite and local operations through the use of 

alternative fuel vehicles or hybrids; and increasing the use of video and teleconferencing to 

reduce the environmental impacts of air travel

Materials. Reducing the use of materials and the creation of waste by reducing, reusing, and 

recycling materials needed for laboratory operations; increasing the purchase and use of 

environmentally sensitive products and products with recycled content

Environmental Management. Providing an environment that promotes efficiency, 

effectiveness, and sustainability, and encourages the creativity and personal motivation required 

for excellence in scientific, engineering, technology development, and support functions

Education/Communication. Informing and providing outreach to workers about sustainability 

activities, including a method for interaction and feedback; educating workers about 

participating and contributing to sustainable activities; informing workers and the public about 

NREL’s environmental performance, including a method for interaction and feedback

Compliance with Requirements. Complying with applicable federal, state, and other 

environmental requirements and exceeding those requirements, when feasible, by implementing 

environmental best management practices.

Public Responsibility. Working with local stakeholders to identify and implement collaborative 

projects to improve sustainability of the local community; educating others about sustainability 

through a variety of outreach mechanisms.

4.1 Policy
NREL Environmental Performance Report- 2009 Page 26

4.1.1 Significant Aspects

In 2009, staff reviewed the organization’s potential impacts to the environment and reconfirmed 

without changes its determination of ―significant environmental aspects‖:

Emissions to air

Surface water releases

Wastewater releases

Accidental releases

Solid waste generation and management

Hazardous waste generation and management

Source reduction, reuse, or recycling

Purchase of Environmentally Preferable Products (EPP)

Energy Use

On-site energy generation using renewable sources, and use of energy efficiency technologies

Water use

Other natural resources and raw materials use

Impacts to land, including restoration

Impacts to wildlife or vegetation, including habitat impacts and preservation

Impacts to groundwater

Impacts on communities (e.g. traffic noise, vibration, odor, visual appearance, etc.), including 

benefits.

Each of these aspects is addressed by the management system through elements such as operational 

controls and objectives and targets. The 2009 objectives are described in Section 4.2 below.

4.1.2 EMS Effectiveness - Benefits to the Environment and NREL

NREL’s management system has been in place since the 1990s and has seen numerous benefits over 

the years. Here is a summary of some of those benefits.

Reduced risk. Safe Operating Procedures are developed based on a hazard identification and risk 

analysis process which incorporates environmental risk assessment.

Cost savings. Any avoided impact represents cost savings, specifically in the event of spills and 

incidents.

Environmental awareness. Staff are made aware of the potential environmental impacts from their 

work activities through a variety of mechanisms including broad communications in the NREL Now 

newsletter and postings on the NREL intranet, as well as through activity specific trainings and 

procedures.

Empowered individuals. Staff are empowered to reduce NREL's environmental footprint including 

participation in programs and events for recycling single-stream materials, batteries, electronic 

equipment, and shredded paper, as well as a pilot composting program. Staff at the new Research 

Support Facility are able to support a new ultra high efficiency energy goal for the building by 

reducing their energy use in the office. Researchers are participating in a self-inspection program for 

hazardous wastes generated in their own labs. Increased responsibility and awareness of lab wastes 

will likely reduce the amount of wastes generated.
NREL Environmental Performance Report- 2009 Page 27

Organizational culture and operations. NREL strives to maintain high level of awareness in the 

laboratory around safety, health, and environmental issues. This is accomplished through a variety of 

means, including regular communications from executive management, as well as at the ground level 

through each interaction of EHS staff with lab and operations staff in trainings, inspections, risk 

assessments, and daily interactions.

Real Property Asset management. NREL strives to achieve LEED Gold ratings for all new 

buildings and major renovations.

Community relations. NREL seeks to improve community relations by responding to and tracking 

all community input through phone calls, email, community meetings, and the NEPA process. NREL 

takes proactive measures to engage the community with public tours, newsletters, and mailings to 

neighborhoods surrounding its facilities.

Mission. NREL's EMS supports the organization's overall mission and improves effectiveness by 

systematically addressing environmental opportunities and risks, ensuring compliance with 

regulations, and going beyond mere compliance.

Cooperative conservation. NREL regularly works with community stakeholders to improve the 

community. For example, with the growth of the South Table Mountain campus, NREL implemented 

a Traffic Mitigation Plan to reduce forecasted impacts of increased traffic to the facility.

While NREL benefits as an organization from each of the efforts highlighted here, the larger benefit 

is in reduced impacts to the quality of the air, water, land, and to the flora and fauna that share the 

campus and community. 

4.1.3 Notable 2009 Activities 

4.1.3.1 Federal Electronics Challenge 

In 2009, NREL achieved the Gold-level Federal Electronics Challenge (FEC) Award. FEC is a 

partnership program between the Office of the Federal Environmental Executive and the EPA. The 

FEC recognizes federal facilities that voluntarily:

Purchase greener electronic products

Reduce impacts of electronic products during use

Manage obsolete electronics in an environmentally safe way. 

To learn more about the award, please see the NREL FEC poster summary (PDF 4 MB). Learn more 

about this voluntary program at the Federal Electronics Challenge Web site at

http://www.federalelectronicschallenge.net/.

4.1.3.2 External EMS Audit

In May of 2009, NREL completed an external audit of its management system. The audit identified 

non-conformities with the ISO14001 requirements for which corrective and preventive action plans 

were developed to address the issues identified. These issues ranged from lack of awareness of the 

environmental policy, to references in system documents, to obsolete or out of date documents. To 

date, several action plans have been completed while other longer term corrective action plans are 

still in progress.
NREL Environmental Performance Report- 2009 Page 28

4.1.3.3 Colorado Environmental Leadership Program

NREL continued progress toward environmental performance commitments made as a Gold-level 

Leader in Colorado’s Environmental Leadership Program (ELP). The Colorado ELP is the voluntary 

partnership between Colorado Department of Public Health and Environment (CDPHE) and 

participating private and public Colorado facilities, recognizing environmental leadership and 

performance. 

In early 2004, NREL was the first laboratory accepted into the Colorado ELP as a Gold-level leader 

and has maintained this leadership level ever since. NREL sets voluntary three-year environmental 

performance goals as a component of ELP membership in an effort to further enhance operations and 

performance at the laboratory. The current goals were established in 2007 and are described in detail 

in Section 4.2.2.1 below.

The CDPHE ELP recognizes facilities that voluntarily:

Exceed regulatory requirements

Implement EMSs (which focus on incorporating environmental considerations into normal 

management processes and improving internal environmental management effectiveness)

Work closely with their communities

Set three-year goals focusing on measurable results.

Learn more about this voluntary program at the Colorado Department of Public Health and

Environment Web site at http://www.cdphe.state.co.us/el/elp/index.html.

4.1.4 Public Outreach

NREL provides a number of avenues for communication between the Laboratory and the 

community, such as community meetings, public facing websites, periodic newsletters and mailings. 

NREL tracks and responds to all environmentally related concerns through the Public Affairs office.

4.2 Performance Indicators and Progress

4.2.1 2009 Environmental Objectives and Progress toward Goals 

Each fiscal year, in collaboration with DOE-GO, NREL develops environmental performance 

objectives for the upcoming year as part of the lab’s One-Year Plan. The FY 2009 goal was ―to 

demonstrate that ES&H is a priority; that processes and practices are in place to effectively identify 

and manage risks to protect NREL workers, the local community, and the environment; and that the 

laboratory complies with all applicable DOE requirements, regulation, laws, and laboratory policies 

and procedures.‖ 

For FY 2009, the environmental objectives were: 

A safe and healthful workplace based on identified and managed risks

Further ISM through the development of improved management systems

Transform environmental excellence to a sustainability strategy

NREL successfully completed the One-Year Plan objectives. Some noteworthy achievements in FY 

2009 include:

Supported lab growth by implementing an Advanced EHS Orientation course, which allows 

workers to spend time (2-3 weeks) in their work areas then return for advanced safety 
NREL Environmental Performance Report- 2009 Page 29

training on chemical safety, pressure safety, lockout tagout, electrical safety, and hazardous 

waste management.

Supported the installation of a solar array–worked with to control fall hazards on the rooftop 

of the S&TF.

Relocated prairie dogs at the NWTC impacted by the installation of a solar array.

Identified hazards associated with accumulated wood dust, and issues associated with smoke 

emissions and opacity at the RFHP. Developed and implemented appropriate controls to 

address these issues.

Traffic mitigation plan implemented to alleviate forecasted traffic congestion from the RSF 

and ESIF population growth at the South Table Mountain site.

NEPA review completed for the Supplement II to Site-wide Environmental Assessment–

South Table Mountain Complex.

Sustainability Program Director position established, elevating leadership in sustainable 

operations consistent with NREL’s values and mission.

4.2.2 State of Colorado ELP Commitments (2007–2010)

4.2.2.1 Current commitments

The following multi-year commitments were made to CDPHE’s ELP program for 2007 through 

2010. 

Campus Planning

Sustainable buildings 

o NREL actively ―walks the talk,‖ having made a tremendous start by achieving 

Leadership in Energy and Environmental Design (LEED) Platinum designation at the 

Science and Technology Facility (S&TF) in March 2007. NREL plans to attain 

LEED Gold or better for all future building design and construction. For planning 

purposes, NREL developed a Grand Buildout Plan, including design of the 222,000 

gross square foot (gsf) Research Support Facility (RSF). NREL’s STM buildout plan 

calls for growing from 400,000 gsf to 1,100,000 gsf, and from 450 occupants to 2,700 

occupants. As mentioned in Section 1, the RSF, like the S&TF, is on track to be 

LEED Platinum.

GHG 

o NREL committed to exceed the 3% FY 2007 GHG reduction required by EO 13423. 

This will be completed through the deployment of energy efficient and renewable 

energy technologies on site at NREL, and through the purchase of renewable energy 

certificates

Electronics

o NREL’s goal was to apply for acceptance into the Federal Electronics Challenge 

(FEC), and complete 19 projects in order to apply for the 2007 FEC Silver-level 

Award given jointly by the Office of the Federal Environmental Executive and the 

U.S. EPA.

Results:

NREL has successfully achieved its ELP commitments for 2009. 

Sustainable buildings 
NREL Environmental Performance Report- 2009 Page 30

o All laboratory new construction complies with the Guiding Principles for Federal 

Leadership in High Performance and Sustainable Building. As of FY 2009, 13% of 

NREL’s existing building inventory incorporates the sustainable practices in the 

Guiding Principles. With the completion of the RSF I in FY 2010, NREL will have 

exceeded its FY 2015 15% goal. 

GHG 

o NREL easily exceeded the 3% per year GHG reduction goal required by the federal

Executive Order 13423, Strengthening Federal Environmental, Energy and 

Transportation Management. In addition, NREL successfully achieved its Climate 

Leaders goal of reducing its total GHG emissions by 75% from FY 2005 to FY 2009.

NREL has exceeded this goal to totally offset the laboratory’s CO2 footprint with 

energy retrofits, onsite renewable energy projects, minimum Gold level ratings of the 

Leadership in Energy and Environmental Design (LEED) standards for new 

construction and ―green power‖ purchases of RECs and carbon credits.

Electronics

o NREL was awarded the 2009 EPA Federal Electronics Challenge Gold Level Award, 

recognizing NREL’s efforts toward environmentally sound management of electronic 

waste management/recycling and sustainable electronic purchasing.

4.2.2.2 Future Commitments

NREL has submitted the following commitments for 2011 through 2013:

NREL will demonstrate environmental leadership by attaining ISO 14001 Registration for its 

environmental management system.

Implement a Pollution Prevention Initiative Program to identify P2 opportunities and provide 

resources and funding to achieve desired results.

Increase on-site renewable energy generation by 100% to approximately 4MW.

NREL will participate in the Sustainable ―SITES‖ Initiative Pilot Program and obtain Pilot 

Certification.

4.2.3 2010 Environmental Objectives 

The environmental objectives developed by NREL in collaboration with DOE-GO are to meet the 

Environment, Safety, and Health (ES&H) Management goal stated in the Performance Evaluation 

Measurement Plan. The FY 2010 goal is ―to demonstrate that ES&H is a priority; that processes and 

practices are in place to effectively identify and manage risks to protect NREL workers, the local 

community, and the environment; and that the laboratory complies with all applicable DOE 

requirements, regulation, laws, and laboratory policies and procedures.‖ 

For FY 2010, the environmental objectives are: 

A safe and healthful workplace based on identified and managed risks

Further ISM through the development of improved management systems

Transform environmental excellence to a sustainability strategy.

Progress toward the 2010 objectives will be reported in the NREL 2010 Environmental Performance 

Report.
NREL Environmental Performance Report- 2009 Page 31

4.3 Assessment and Improvement

Periodic assessment and management review of NREL’s EMS and its components provide 

verification that the EMS continues to be an effective tool to achieve and maintain compliance with 

regulatory and legal requirements, meet the established environmental goals of the laboratory, and 

maintain management support for NREL’s environmental goals. Assessments and management 

reviews also provide for continuous improvement of the EMS. 

There are three different types of assessments performed to evaluate the functionality of the EMS at 

NREL: EMS assessments, periodic compliance assessments, and third-party assessments. 

A team of NREL staff generally performs periodic assessments of NREL’s EMS internally, as 

occurred in February 2009. The scope of the assessments includes both the management of 

significant environmental aspects (areas where NREL activities have the potential for environmental 

effects, either positive or negative) and policy implementation. The team evaluates the EMS based on 

an appropriate set of criteria, such as ISO 14000 standards, DOE Order requirements, Colorado 

Environmental Leadership Program standards, or other applicable environmental management 

standards. 

Periodic compliance assessments are conducted of individual environmental programs to verify that 

each program, as written, meets all applicable legislative and regulatory requirements and that the 

program is implemented as intended (see Section 5.0 for examples). Improvements are developed 

and implemented as necessary, based on the results of each assessment. 

In addition to compliance assessments of individual NREL environmental programs, NREL has 

management system review processes in place for regular reviews and updates of the set of policies, 

lab-level programs, and task-specific procedures, including EMS policies and programs. NREL 

reviews its EHS policies and laboratory-level procedures as needed, but at least every five years, 

based on their risk rating, making revisions as necessary. All SOPs are reviewed on an annual basis 

and are revised as necessary to help ensure the required controls are appropriate for the hazards 

present. Environmental hazards and controls are specifically called out in each SOP. 

Periodically, external third-party assessments may be conducted by technical experts for specific 

components of NREL’s environmental programs or for the EMS as a whole. These assessments are 

conducted on an as-needed basis. A third-party, external audit of the EMS was conducted in 2009 

and similar audits are planned for every three years, as required by DOE Order 450.1A.

4.3.1 2009 Assessment Activities

An internal Quality Assurance assessment was conducted on the EMS in February 2009 in 

preparation for an independent audit planned for mid-year.

In May of 2009, NREL received an independent assessment of its EMS to measure the system’s 

sufficiency and effectiveness. The assessment was based on the ISO 14001:2004 standard, the 

NREL EMS description, and any related process documents such as lab-level and desk procedures. 

The assessment consisted of documentation review, site visits, and interviews with EMS staff and 

other workers involved with or affected by the EMS. Several recommendations for improvement 

were identified. A number of corrective and preventive actions were completed in 2009 and several 

longer term fixes are underway to address all remaining issues identified.
NREL Environmental Performance Report- 2009 Page 32

Annual EMS internal assessments will continue to monitor performance of the system. In addition, 

NREL is seeking ISO14001 3rd party certification for its EMS in 2011. For this, an external 

assessment will take place initially and will reoccur on a regular basis to maintain certification.

4.4 Sustainability and the Environmental Management System

NREL’s mission has always focused on a sustainable energy future for our nation and the world. 

Sustainability is defined as meeting the needs of the present without compromising the ability of 

future generations to meet their needs, and involves the simultaneous and balanced pursuit of 

economic viability, environmental stewardship, and public responsibility. 

The Sustainable NREL program was created to realize the vision of greater sustainability in NREL 

operations. It is an interdisciplinary initiative involving staff from numerous NREL centers and 

offices with the goals of maximizing efficient use of resources; minimizing waste and pollution; and 

serving as a positive force in economic, environmental, and public responsibility. Elements of the 

environmental stewardship component of Sustainable NREL include: 

Renewable energy solutions 

Sustainable green buildings, campus planning, and transportation 

Water, electricity, and natural gas use reduction 

Greenhouse gas emission reductions 

Reduce, reuse, and recycle materials use 

Public responsibility/community outreach 

Environmental management. 

Sustainable NREL carries out the laboratory’s commitments to, among other things, reducing energy 

use in its building operations, designing energy efficient and environmentally sensitive new 

buildings, reducing water consumption, decreasing GHG emissions, minimizing the impact of NREL 

local and air travel on the environment, using less fossil-based fuel for local operations, incorporating 

renewable energy technologies into its on-site STM and NWTC operations, and creating less waste 

by reducing, reusing, and recycling materials for laboratory operations. 

In addition, the EMS supports Sustainable NREL’s goals by focusing on protecting the natural and 

cultural resources on and around NREL sites by: 

Reviewing NREL’s potential for environmental impacts through emissions, discharges, waste 

generation, purchases, and land use

Conducting required permitting activities

Managing site natural resources for protection and preservation of their natural character to 

the extent possible, while still fulfilling NREL’s mission

Managing site cultural resources for documenting resources of significance and minimizing 

disturbances whenever possible

Recommending and coordinating measures to minimize any potential impacts NREL’s 

activities have on the environment. 

4.4.1 2009 Results

The following information is excerpted from Sustainable NREL’s 2009 Sustainability Report. Please 

see www.nrel.gov/sustainable_nrel for the full report.
NREL Environmental Performance Report- 2009 Page 33

NREL has accepted DOE’s challenge to provide environmental stewardship leadership in the DOE 

complex by achieving or exceeding DOE Order 430.2B. By actively working to maintain a 

sustainable environment in our own workplace the laboratory demonstrates its commitment to 

minimal use of resources and balance environmental, economic, and human impacts.

Energy Efficiency

Energy use reduction on NREL’s campus is focused on the design and construction of highly energyefficient new buildings (see the section on Sustainable Green Buildings). Cost-effective energyefficiency retrofit opportunities have, for all practical purposes, been implemented. Specifically, 

NREL expects to exceed the required FY 2015 energy use intensity reduction goal of 30% by 

significantly exceeding the energy use requirements of the federal energy efficiency new construction requirements.

Renewable Energy

NREL’s Mesa Top PV system located in Golden, Colorado has a 750 kW capacity and generated 

1015 MWh of electricity from January 1, 2009 to September 30, 2009. This electrical production 

represents 7% of NREL’s STM site electrical consumption. This system was installed under Power 

Purchase Agreements (PPAs) with a third-party developer; an additional system will be purchased 

utilizing appropriations. The Mesa Top PV system was the first DOE PPA agreement. Additional onsite renewable energy projects are in the process of being completed. PV is planned for all new major 

buildings. 

Energy Use Reduction Goal 

DOE Order 430.2B. Beginning in FY 2006 improve energy efficiency through reduction of energy use 

intensity by 3% annually through the end of FY 2015 or 30% by the end of FY 2015 as compared to 

the baseline energy use in FY 2003. 

Progress. In FY 2009 NREL’s energy use intensity decreased 7% from our FY 2003 baseline. This 

did not include the allowable Renewable Energy Credit (REC) reductions. NREL will exceed the FY 

2015 goal through the significant additions of highly energy efficient new buildings (exclusive of the 

use of RECs).

Renewable Energy Generation and Use Goals 

DOE Order 430.2B. Use of renewable energy shall be 3% for each year from FY 2008 through FY 

2009; 5% from FY 2010 through FY 2012; and 7.5% from FY 2013 forward. At least half of the 

statutorily required renewable energy consumed each fiscal year shall come from “new” (post January 

1, 1999) renewable sources. 

Progress. FY 2009 renewable energy use was 100% of annual electric consumption achieved 

primarily through the utilization of on-site renewable energy projects and the purchase of RECs. One 

hundred percent of the renewable energy use was from “new” renewable energy resources. These 

results significantly exceed the FY 2013 renewable energy electric generation and use goals.
NREL Environmental Performance Report- 2009 Page 34

A 1.5 MW wind turbine, purchased by DOE, was installed at the NWTC on August 21, 2009; it 

began operation in October 2009. The estimated production from the DOE turbine is 1,600,000 

kWh/year (enough to serve 142 homes). In FY 2010 NREL plans to sell the power produced by this 

R&D turbine to the grid through a ―sale of power‖ agreement with the local utility. The Siemens 2.3 

MW turbine, installed at the NWTC on September 24, 2009, has an estimated production of 

2,800,000 kWh/year (enough to serve 249 homes). It began operation in October 2009. 

The thermal output of the Renewable Fuel Heating Plant (RFHP) positions NREL to significantly 

exceed the DOE Order 430.2B renewable energy thermal generation goal (7.5% of annual thermal 

energy use by FY 2013). The RFHP was installed through an energy savings performance contract 

(ESPC).

In support of our mission and this DOE mandate, we continue to proactively pursue sustainability in 

all of our operations–incorporating on-site renewable energy projects as described in the following 

table.

 *Scheduled operation dates

Carbon Footprint 

NREL began tracking its CO2 emissions in FY 2003. NREL quantifies its ―carbon footprint‖ by 

including emission sources beyond the laboratory’s boundary, such as laboratory leased space, air 

travel, and the commuting of staff members to and from work. Sources with negligible emissions 

such as fleet vehicle emissions, solid waste disposal, and water (associated electricity or natural gas 

consumed) are not included in the graph. 

Site Rating Annual Energy Operational Year

South Table Mountain 

Mesa Top

720 kW 1,200,000 kWh 2008

Science and Technology 

Facility (S&TF)

94 kW 134,813 kWh 2009

National Wind Technology 

Center (NWTC)

1,083 kW 1,913,661 kWh 2009

Research Support 

Facility1(RSF I)

741 kW 976,009 kWh 2010*

RSF1 Parking Garage 630 kW 829,710 kWh 2010*

Totals 3,268 kW 5,054,193 kWh

SOURCE Kg CO2 Eq.

Electricity 19,306,657

Natural Gas 3,807,131

Commuter Vehicle Emissions 5,328,288

Domestic Air Travel Emissions 2,706,567

International Air Travel Emissions 707,823

Fleet Vehicle Emissions 249,893

On-site Renewable Energy Electric Generation
NREL Environmental Performance Report- 2009 Page 35

The quantification of this footprint provides a metric which allows the laboratory to: 

Take into account the carbon implications of its investment decisions 

Measure progress towards achieving carbon reduction goals 

Benchmark performance 

Take responsibility for its actions.

Note for 2009: GHG offsets achieve 100% reduction from base year.

Greenhouse Gas Reduction 

Greenhouse Gas (GHG) Reduction Goals 

DOE Order 430.2B. Reduce GHG emissions by 3% annually, or 30% by the end of FY 2015, relative to 

GHG emissions in FY 2003. 

NREL Goals. NREL will achieve “carbon neutrality” annually. NREL has pledged through the 

Environmental Protection Agency (EPA) Climate Leaders Program (CLP) to reduce its total U.S. GHG 

emissions by 75% from 2005 to 2009.

Progress. In conjunction with energy use reduction performance, NREL is exceeding the DOE GHG 

reduction goals. NREL has met its FY 2009 EPA Climate Leaders GHG reduction goal.

0%

20%

40%

60%

80%

100%

120%

0

2000

4000

6000

8000

10000

12000

14000

16000

2005 2006 2007 2008 2009

Total GHG (metric tons)

Inventory Year

Climate Leaders Program - NREL Total GHG Emissions

Total 

GHG

60%

12%

17%

8%

2%

1 %

FY 2009 CO2 Emissions Breakdown

Electricity

Natural Gas 

Commuter Vehicle Emissions 

Domestic Air Travel Emissions

International Air Travel Emissions

Fleet Vehicle Emissions
NREL Environmental Performance Report- 2009 Page 36

New federal GHG reduction requirements are expected to be mandated as soon as 2010. These 

mandates will focus on GHG emission measurement and reduction and utilize these reductions as its 

primary metric.

NREL is well positioned to provide leadership in this area, having established a GHG emission 

inventory with reduction goals since FY 2000 through the EPA CLP. NREL met its first goal in FY 

2005 reducing its GHG emissions by 10% from the FY 2000 baseline. The laboratory set a second 

CLP goal of reducing its total GHG emissions by 75% from FY 2005 to FY 2009. NREL has 

exceeded this goal to totally offset the laboratory’s CO2 footprint with energy retrofits, onsite 

renewable energy projects, minimum Gold level ratings of the Leadership in Energy and 

Environmental Design (LEED) standards for new construction and ―green power‖ purchases of 

RECs and carbon credits.

Campus–Sustainable Green Buildings

The first priority of the NREL campus energy strategy is to invest in site design and building 

development to maximize energy efficiency with appropriate building orientation and mass. This 

strategy takes advantage of passive solar design for heating, cooling, and natural lighting in all new 

building construction. Low-energy design strategies in office buildings focus primarily on reducing 

energy for lighting and cooling. Strategies in laboratories focus on reducing the energy needed to 

meet ventilation requirements.

NREL’s new major building, the RSF, is a 220,000 sq. ft. office building scheduled for occupancy in 

June 2010. The RSF is a design-build project with a conservative energy budget of 32,000 Btu/sq. ft. 

The RSF is also being designed as a highly energy-efficient building at the LEED Platinum level.

Increased demand for renewable energy and energy efficiency technologies requires critical 

laboratory space and partnering facilities. Attributes of the planned space include energy efficiency, 

carbon neutrality, and LEED Platinum or Gold certification.

In addition, NREL manages the impact on the environment caused by the placement and general 

design of NREL structures–maintaining, protecting, and restoring natural and landscaped 

environments to sustain natural and native ecological systems, both on and adjacent to NREL 

campuses.

Transportation

Sustainable Design/High Performance Buildings Goals

DOE Order 430.2B. New construction and major renovations shall comply with the Guiding Principles 

for Federal Leadership in High Performance and Sustainable Building (Guiding Principles). Fifteen 

percent of the existing building inventory as of the end of FY 2015 will incorporate the sustainable 

practices in the Guiding Principles. DOE sites will achieve a LEED Gold rating on all new buildings.

Progress. All laboratory new construction complies with the Guiding Principles. As of FY 2009, 13% of 

NREL’s existing building inventory incorporates the sustainable practices in the Guiding Principles. With 

the completion of the RSF in FY 2010, NREL will significantly exceed the FY 2015 15% goal.

Petroleum and Alternative Fuel Use Goals

DOE Order 430.2B. Reduce total fleet petroleum product consumption by 2% annually through the end 

of FY 2015 as compared to the FY 2005 baseline.

Increase the total fleet fuel consumption that is nonpetroleum-based by 10% annually.

Progress. NREL made negative progress in this area. See narrative below.
NREL Environmental Performance Report- 2009 Page 37

Alternative-fuel vehicles and bio-based fuels

NREL’s fleet of vehicles currently consists of one diesel commercial leased vehicle and 46 GSA 

vehicles. Thirty-six of the fleet use alternative fuels, three use diesel, and seven use unleaded 

gasoline. 

In FY 2009, NREL’s fleet consumption increased significantly. The use of E85 fuel increased 34% 

due to (but not limited to) several factors.

E85 fuel was not made available at the nearest E85 station (within 5 miles or 15 minutes)

NREL’s on site FAST CNG (compressed natural gas) station has been inoperable since April 

2009

Local mileage increased

The alternative fuel vehicles used for snow removal were unable to fuel with alternative fuel 

due to fuel unavailability. 

NREL replaced two GSA1 CNG dedicated 15-passenger vans with two GSA diesel buses to 

assist in shuttling NREL’s employees on site. NREL’s shuttles are increasingly used to 

transport employees to and from local bus stops and for tours, visitors, etc. Fewer employees 

are using their personal vehicles onsite.

NREL replaced one GSA Bi-Fuel CNG pickup truck with a C4500 unleaded box truck to 

assist NREL’s Shipping and Receiving (S&R) Department with their deliveries to include 

(but not limited to) gases, chemicals, large research equipment, etc. The smaller vehicle did 

not meet the requirements which impacted S&R’s mission.

Traffic Management

To help ease traffic concerns, address planned parking management, and to decrease the reliance on 

single occupant vehicle trips, NREL developed a transportation program to manage traffic at the 

STM site. 

In 2007, a team of consultants, Felsburg, Holt, and Ullevig and Urban Trans Consultants, completed 

the Traffic Impact Analysis that became the basis for a Mitigation Action Plan (MAP) required to 

allow several projects to proceed on the STM campus (the MAP is also discussed in Section 5.15, 

below). The analysis predicted that relocating approximately 800 employees to the Research Support 

Facility, combined with growth in the employee population would result in an increase of daily trips 

to the STM from 1934 to 5530 in 2010. Mitigation actions were identified that would reduce this 

impact, with a goal of decreasing peak hour trips by 24%.

The specific recommendations included in the plan address internal policies and programs, trip 

linkages, transit accessibility, parking management, and on-site transportation demand management 

strategies all of which enable NREL to address traffic and parking objectives. 

The MAP will be implemented in three phases:

1. Startup (2008-2010).

2. Occupancy, which will begin when employees at Denver West Office Park begin to relocate 

to the STM site.

 

1 The GSA vehicles replaced were determined by GSA’s replacement criteria (i.e., age, mileage, or the combination 

of both). The request to increase the size of the vehicle(s) and the type of fuel was approved by NREL and DOE 

Golden Field Office. This was necessary due to the increase in FTEs in FY 2009 and the fact that staff is located in 

several new leased facilities spread out through the Denver West Office park and STM campus.
NREL Environmental Performance Report- 2009 Page 38

3. Buildout of the STM site. 

A summary of the mitigation strategies is present in Table 1:

TABLE 1: Mitigation Strategies

In 2009, several key mitigation measures were implemented, including transit subsidies, 

telecommuting and flextime, and hiring a Transportation Program Coordinator to ensure compliance 

with the MAP. Some initial results from these efforts are reported below.

Alternative modes of commuting

• Free Eco Passes to use the Regional 

Transportation District (RTD) 

public transportation–unlimited 

RTD regional, express, local, light 

rail, and Call-n-Ride services. 

• Alternative-fuel shuttle vehicles that 

reduce miles traveled at its STM and 

Denver West sites in Golden, 

Colorado. 

Flexible work place practices 

Conferencing by video, telephone, and the 

internet as well as alternative work 

schedules (AWS) provide flexibility in 

how people work–saving time, energy, 

0

50

100

150

200

250

106 100 86

104

35 19

Number of Employees Telecommuting & AWS

after June 2009

before June 2009

Source: Self Reported by CD & OD
NREL Environmental Performance Report- 2009 Page 39

and money. An AWS policy allows employees to work varying schedules (with management 

approval), including four-day workweeks–reducing the miles driven by employees to and from the 

laboratory.

Telecommuting Program

A Telecommuting Pilot program began in FY 2009 and was offered to employees in twelve NREL 

Offices and Programs. The pilot program’s success is resulting in a laboratory-wide program which 

will be available to all NREL employees in FY 2010. There are many benefits in telecommuting 

including: 

• High Performing Workforce. Higher morale and commitment, improved recruitment and 

retention of global talent 

• Sustainability. Reduced CO2, energy use, 

waste generation, facility size, parking 

requirements, traffic impact on- and off-site 

• Economics. Reduce employee commuting 

costs (fuel and vehicle maintenance)

• Supports work-life balance. 

International and domestic air travel represents 63% 

of the total commuter miles traveled. The pie chart 

summarizes the various commuting methods used 

by NREL. However the use of video conferencing, 

webinars, etc., displaced approximately 553 flights, 

3,300 air miles, and 3,868 hours of flight time. This calculation was based on activities of the 

Laboratory’s two main offices located in: Golden, Colorado and Washington D.C. In FY 2009, it is 

estimated that NREL’s audio, video conferencing, and webinars increased approximately 45% from 

FY 2008.

Water Conservation

The FY 2007 NREL water consumption baseline is 13.2 million gallons or a water consumption 

intensity of 28.7 gallons/sq. ft. In 2009, NREL reduced its water consumption by 27% relative to the 

FY 2007 baseline. For FY 2009, the laboratory had a water consumption intensity of 20.79 

gallons/sq. ft. The table below shows the total annual laboratory water consumption from FY 2005 to 

FY 2009.

NREL will incorporate water conservation measures in all new construction facilities as a part of 

achieving the minimum LEED Gold certification. Meeting LEED requirements will result in a 34% 

water consumption reduction at the RSF. Based on the RSF design; this facility will consume 

Water Use Reduction Goal

DOE Order 430.2B. Beginning in FY 2008, NREL will reduce water consumption intensity by 2% 

annually through the end of FY 2015 or 16% by the end of FY 2015, relative to the baseline water 

consumption in FY 2007. 

Progress. In FY 2009, NREL reduced its water consumption by 27% relative to the FY 2007 baseline.

To exceed the overall reduction goal of 16%, NREL will continue to incorporate water saving measures 

in all new construction facilities to achieve the minimum LEED Gold rating.

1%

63%

34%

-2%

Fleet

Air

Commuter

Tele/Video 

Conferencing

FY 2009 Commuter Miles
NREL Environmental Performance Report- 2009 Page 40

786,700 gallons of water–a water consumption intensity of 3.6 gallons/sq. ft. For existing building 

water conservation retrofit goals have been established and are being implemented.

Material Use

NREL is working toward near-zero waste–taking the 4Rs program (reduce, reuse, recycling, and rebuy) to a higher level–systematically eliminating the laboratory’s waste stream.

Reduce

NREL reduces material use by: 

Replacing paper drafts with electronic files

Installing duplex modules on all network printers for double-sided printing option

Reusing cardboard boxes, packing peanuts, plastic containers, and drums

Material Use Goals: 

DOE Order 430.2B. Ensure that the laboratory reduces the quantity of toxic and hazardous 

chemicals and materials acquired, used, or disposed of by the laboratory; increase diversion of solid 

waste as appropriate; and maintain cost effective waste prevention and recycling programs.

NREL Goal. Near Zero Waste (working to eliminate the laboratory’s waste stream).

Progress. Since FY 2003, NREL’s recycled waste has increased by 58%, even with our campus 

increasing by 117,263 sq. ft. This does not include scrap metal, batteries, e-waste, and other items. 

NREL has implemented comprehensive reduce, reuse, recycling, and re-buy activities 

NREL reduced its water consumption by 27% in FY 2009 relative to the FY 2007 baseline.

-

2,000,000 

4,000,000 

6,000,000 

8,000,000 

10,000,000 

12,000,000 

14,000,000 

16,000,000 

NREL Water Consumption

FY05 FY06 FY07 FY08 FY09 Gallons of Water
NREL Environmental Performance Report- 2009 Page 41

Sharing chemicals and redistributing extra chemicals through a chemical management 

system.

Reuse

NREL’s Reusable Office Supply Depot provides opportunities for centers and offices to save money 

and help the environment by reusing office supplies that could end up in a landfill. Staff members are 

encouraged to take (and reuse) office supplies from the depot or donate any new or good-as-new

items for others to use.

Recycle

NREL’s long-established recycling effort includes a recycling station in each building. All recyclable 

materials are comingled in specified bins; there are separate bins for large cardboard; containers for 

batteries; designated areas for printer toner cartridges; and each office /cubicle contains a small 

recycle basket. Scrap metal, wooden pallets, computer monitors, and fluorescent light bulbs are also 

recycled.

Prior to FY 2005, all recycled materials were separated and weighed and a monthly report was 

provided to NREL. In FY 2005 the recycling vendor went to a single stream, comingled pick-up.

They were unable to give weights and provided NREL with estimates based on the different sizes of 

recycle bins. In FY 2009 they provided NREL with a measurement system to more accurately 

calculate the weights for each pick-up.

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

FY06 FY07 FY08 FY09

Weight in Pounds

FY06 - FY09 Total Waste Comparison

Recycled Waste 

Materials

Solid Waste

Note: FY2008 Solid Waste data includes a non-routine clean-up at the NWTC. This increased NREL’s 

solid waste generation rate significantly–many materials were not recyclable (e.g., fiberglass turbine 

blades), but all scrap metal was recycled which is reflected in the chart below.
NREL Environmental Performance Report- 2009 Page 42

Re-buy

NREL makes green purchasing possible through an online catalog featuring environmentally preferable (recycled content). These items include binders, paper, pens, post-its, calendars, file folders, 

etc. The laboratory’s biggest purchase is of recycled toner cartridges which totaled $96k in FY 2009.

Since 1999, 100% of all carpet and office paper have contained recycled content.

Other Recycled Items(by pounds)

Breakdown of Recycled Materials FY06 FY07 FY08 FY09

Scrap Metal 35,460 39,263 456,150 268,620

Batteries 4,304 3,803 64,595 11,905

Fluorescent light bulbs 1,058 426 260 661

Computer monitors 2,384 2,640 39,860 4,950

Wood 0 0 33 40,500

E-Waste 0 0 0 19,280

Concrete

0 0 8,106,397 0
NREL Environmental Performance Report- 2009 Page 43

5 Environmental Programs

The overarching objective of NREL’s EMS and its component programs is responsible stewardship 

of the environment on its DOE-owned sites, leased properties, and to the extent practicable, on 

subcontractor and partner sites. NREL strives to protect the natural environment by minimizing or 

eliminating any adverse environmental impacts resulting from NREL activities. The laboratory’s 

EMS is integrated with other NREL management systems and applies to all research and operations 

activities. The EMS includes written environmental protection policy and program implementation 

documents. These are put into practice at all staff and management levels. 

NREL’s EMS includes components to address waste, air, water, site, natural, and cultural resources, 

and land and soil issues, among others. Descriptions of the components of the EMS are provided in 

the following sections of this chapter; sections are organized by resource. Each section is composed 

of three areas of discussion: a summary of the environmental management of the resource, a 

discussion of any relevant permitting, and a summary of significant activities that have occurred 

throughout CY2009. 

A summary of NREL’s permits, registrations, and notifications are presented in Appendix A. These 

permits are discussed in the following relevant sections.

5.1 Air Quality Protection

5.1.1 Program Management 

Management in this area is consistent with the following NREL programs: Environmental Permitting 

and Notification (6-2.1), Air Quality Protection (6-2.5), Ozone-Depleting Substances Management 

(6-2.6), and Particulate Emissions Control for Construction (6-2.14). 

5.1.1.1 Criteria, Hazardous, and Non-Criteria Pollutants 

The Clean Air Act and State of Colorado laws and regulations delineate several main categories for 

air pollutants: 

Criteria air pollutants (e.g., carbon monoxide, nitrogen oxides, sulfur dioxide, particulate 

matter, ozone, and lead, all for which National Ambient Air Quality Standards exist)

Non-criteria pollutants (e.g., ammonia, hydrogen sulfide, pesticides, organic compounds 

classified as ozone precursors, metallic compounds, greenhouse gases, and corrosives)

Hazardous air pollutants (e.g., includes organic compounds, metals, corrosives, asbestos, 

radionuclides, and pesticides)

Ozone depleting substances (e.g., chlorofluorocarbons or ―freons‖).

There are notification and permitting thresholds for criteria, hazardous, and non-criteria pollutants. 

The primary potential sources of these pollutants at NREL include boilers, emergency generators, 

experimental laboratory hoods, pilot scale research projects, and small pieces of equipment with 

gasoline or diesel engines. NREL maintains air emission inventories to track potential air emissions 

and identify whether notification and permitting could be required for a particular facility or activity. 

Fugitive particulate emissions from construction activities occurring on NREL’s sites are also a 

potential source.
NREL Environmental Performance Report- 2009 Page 44

5.1.1.2 Ozone Depleting Substances

Facilities that service refrigeration equipment containing ozone-depleting substances (ODS) are 

required to file an annual notification with the CDPHE. NREL employs EPA-certified technicians 

that service ODS-containing equipment. Another requirement of the state’s Chlorofluoro Carbon 

program is that all refrigeration equipment larger than 100 hp that uses ODSs be registered with 

CDPHE. NREL has a total of three chillers that are registered with CDPHE; two located at the Solar 

Energy Research Facility (SERF) on the STM Site, and one at the DWOP. 

Halon-based fire suppression systems previously used at NREL were eliminated by 1999, with all 

supplies of Halon being transferred to other DOE facilities for ―banking.‖

5.1.1.3 Street Sanding 

CDPHE regulations require federal, state, and local government facilities to track street sanding in 

the wintertime, and to make efforts to minimize sand use. NREL complies with this requirement and 

files an annual sanding report with CDPHE. From October 2008 to May 2009, NREL used 79 tons of 

sand during 24 sanding episodes, while continuing to maintain 12.3 lane-miles of road. From October 

2009 to May 2010, NREL used 50 tons of sand and 36 tons of Ice Slice in 25 sanding deployments in 

maintaining 12.3 miles of roadway.

5.1.2 Permitting 

Most potential sources of air emissions from NREL laboratory and facility operations in 2009 were 

of small scale and did not require permitting. Permitting thresholds vary, depending on the pollutant. 

Projected emissions for these sources were below thresholds for air permitting. 

Two site-wide permits for particulate emissions from construction activities have been issued to 

NREL by CDPHE. NREL has held such permits for a number of years. New site-wide permits were 

issued in February 2005 to replace previously held permits for which the time period of applicability 

had expired. One permit covers the STM site and the other covers the NWTC.

Two Air Pollution Emission Notices (APENs) were filed in early 2005, one for the STM and one for 

the NWTC, for overlot grading and associated construction activities to address fugitive particulate 

emissions. The APEN for the NWTC will expire in 2010.

NREL also holds two air emissions permits for an experimental pilot process in the Field Test 

Laboratory Building (FTLB) and the woodwaste-fired boiler in the RFHP, both on the STM Site. The 

pilot process permit was issued in 2000 for the operation of a thermal oxidizer emission control 

device for the experimental Thermochemical Process Demonstration Unit (TCPDU). An APEN

update was filed with the Colorado Air Pollution Control Division in 2005. The RFHP permit was 

issued in 2007.

5.1.3 2009 Activities

In late 2008 NREL filed a new APEN for upcoming major construction activities anticipated in the 

upcoming 5 years at the STM site. Significant activities not associated with routine maintenance or 

small construction projects identified in the APEN submission were evaluated on a case-by-case 

basis in 2009. As a result of this evaluation, it was not necessary to submit an updated APEN.

As required by CDPHE every five years, an APEN update was filed in May 2005 to update the 

information provided in the original APEN for TCPDU activities. There have been no significant 
NREL Environmental Performance Report- 2009 Page 45

changes to the operating parameters or air emissions of the TCPDU in the last several years, 

including 2009. 

In early 2007, NREL received initial approval from CDPHE’s Air Pollution Control Division for the 

construction and operation of a woodwaste-fired boiler to provide building comfort heating for the 

STM campus. Prior to the completion of construction, additional information became available 

regarding the configuration of the equipment and it was necessary to request a permit modification.

CDPHE issued an initial approval for the permit modification in the fall of 2008. Construction of the 

woodwaste-fired boiler was completed and the equipment became operational in late 2008. In April 

2009 NREL completed the self-certification process for final approval and submitted the required 

documentation to CDPHE.

5.2 Drinking Water

5.2.1 Program Management 

Management in this area is consistent with the following NREL Programs: Drinking Water (6- 2.3) 

and Environmental Permitting and Notification (6-2.1).

Drinking water is provided to NREL’s STM and DWOP sites by a public water supply, Consolidated 

Mutual Water Company. Water to the Joyce Street and ReFUEL Facilities is also provided by a 

public water supply. NREL supplies drinking water to its NWTC by trucking in water from local 

public water supplies through a subcontracted water hauler. NREL stores the water on site in a buried 

15,000-gallon storage tank and an above ground 2,000-gallon tank. The water hauler fills the 15,000-

gallon tank, and water is pumped on demand to the 2,000-gallon tank where it is distributed to the 

Industrial User Facility (IUF), Building 251, and the Distributed Energy Resource Test Facility 

(DERTF) on the west end of the site. 

Disinfection boosting is performed at the NWTC using an automated chlorine disinfection system. 

Monitoring for bacteria (total coliforms), chlorine levels, haloacetic acids, and trihalomethanes 

(disinfectant by-products), and lead and copper is performed at the NWTC according to the 

requirements of CDPHE. NREL qualifies for reduced lead and copper monitoring. Current state 

requirements for NWTC system monitoring are as follows: 

• Bacteria–monthly 

• Chlorine levels–weekly, or more frequently as needed 

• Haloacetic acids (HAA5)–annually 

• Total Trihalomethanes (TTHM)–annually 

• Lead and copper–triennially.

Samples are collected from three locations at the NWTC: Building 251, the IUF, and the DERTF. No 

coliforms were detected in any of the samples taken during 2009. Monthly results for the bacterial 

analyses are provided to the state. 

The most recent triennial monitoring for lead and copper was completed as scheduled during the 

summer of 2008. All samples collected were well below the maximum contaminant levels (MCL).

Five sampling locations were tested for lead and copper. Four of the five lead results were below 

detection with the fifth result showing 0.002 ppm, well below the MCL of 0.015 ppm. Copper values
NREL Environmental Performance Report- 2009 Page 46

ranged from 0.095ppm to 0.474 ppm, with an average value of 0.200 ppm, well below the MCL of 

1.3 ppm. The next sampling for lead and copper will occur in 2011.

Chlorine residual monitoring of the NWTC drinking water system began with the installation of the 

chlorine disinfection system in 2000. Monitoring is performed to ensure the chlorine residual levels 

are detectable, with a target concentration of at least 0.2 mg/L of chlorine present to provide 

sufficient disinfection at the monitoring locations. Colorado requires that chlorine residual 

monitoring occur when collecting monthly bacterial samples. NREL monitors chlorine residual 

levels in the system on a weekly basis and also measures chlorine levels of drinking water that is 

delivered to the NWTC. Results are provided to the state on a monthly basis. Chlorine was present at 

appropriate levels in all samples collected in 2009. The running annual average of the maximum 

residual disinfectant level for CY2009 was 0.518 ppm. 

If any treatment is performed on supplied drinking water, state regulation requires that a statelicensed operator supervise the treatment. NREL hires a subcontracted operator with a Class A 

license to supervise the disinfection and filtration operations and to perform the necessary sampling.

5.2.2 Permitting /Notifications

NREL has a registered Public Water Supply Identification Number (PWSID) issued by CDPHE for 

the drinking water distribution system at the NWTC. This identification number does not require 

periodic renewal, but periodic testing, record keeping, and reporting are required. All other NREL 

facilities (STM, DWOP, JSF, GH and ReFuel) are provided drinking water from municipal sources.

5.2.3 2009 Activities

In 2009, 251,040 gallons of potable water were delivered to the NWTC, an average daily 

consumption rate of 687 gallons. NREL conducted all required monitoring in 2009 and all reported 

results met drinking water standards. Bacteria were absent in all samples collected, and disinfectant 

was detected at all locations tested. The annual running average for chlorine was 0.518 ppm.

While monitoring is only required once per year, NREL monitors disinfectant byproducts ( DBPs) on 

a quarterly basis through 2009. The running annual average (RAA) for TTHMs in 2009 was 0.056 

mg/L, below the maximum contaminant level of 0.080 mg/L and in compliance with the water 

quality requirement. The RAA for HAA5s was 0.043 mg/L, below the maximum contaminant level 

of 0.060 mg/L, also in compliance with the water quality requirement.

The 2007 ASER (dated November 2008) first reported that CDPHE’s Water Quality Control 

Division conducted a formal Sanitary Survey of the NWTC drinking water system in 2008. The 

inspection was conducted on September 23, 2008, and the system was found to be in compliance 

with all requirements. Three recommendations for improvement were identified during the survey:

Observation 1. Monitoring and Reporting and Data Verification

―The system should continue to evaluate source water quality from the wholesaler, the system’s 

booster chlorination system, and the amount of residence time in the storage tank, and distribution 

system in order to minimize formation of disinfection by products.‖

Observation 2. System Operations and Maintenance
NREL Environmental Performance Report- 2009 Page 47

―It is recommended that the system develop and implement a valve exercising program for valves in 

the distribution system in order to maximize the life of such devices.‖

Observation 3. Storage Management

―It is recommended that the water system create a tank maintenance plan to evaluate and inspect the 

condition of the buried storage tank and to ensure the tank is a safe and viable component of the 

water system. Preventative maintenance and timely inspections will help prolong the life of the tanks 

and ensure early detection of needed repairs. The water system should examine the tank and piping, 

and look for signs of compromised integrity and leaks on a yearly basis. Additionally, the water 

system should routinely inspect the integrity of the access manhole and vents on a frequent basis to 

ensure the sanitary integrity of these components. In addition to the tank maintenance plan, the water 

system should have the tank drained, cleaned, and professionally evaluated every three to five years 

(as recommended by the American Water Works Association).‖

In 2009, samples of the delivered water were collected and tested for disinfectant byproducts to 

address Observation n 1. Levels of TTHMs and HAA5s were consistent with the running annual 

average. Site Operations has taken the remaining observations under consideration.

5.3 Groundwater

5.3.1 Program Management

Management in this area is consistent with NREL’s Groundwater Protection and Maintenance

Program (6-2.4).

Both the STM and the NWTC are located at the western edge of the Denver Basin aquifer system 

that supplies water to urban, rural, and agricultural users along the Front Range of the Rocky 

Mountains in northeastern Colorado. The aquifers within the Denver Basin, which include the 

Dawson, Denver, Arapahoe, and Laramie-Fox Hills aquifers, form a layered sequence of rock in an 

elongated bowl-shaped structural depression.

The shallowest aquifer is the Dawson formation that is located between 60’-100’ below ground 

surface (bgs) and extends to approximately 1,000 feet bgs. This is followed by the Denver aquifer, 

the Arapahoe aquifer, and finally the deepest aquifer, the Laramie-Fox Hills aquifer which extends 

from approximately 2,270 feet to 2,970 feet bgs. Thicknesses of the aquifers decrease with depth 

below ground surface ranging from 1,100 feet in the Dawson, 400-800 feet in the Denver, 500-600 

feet in the Arapahoe, and 200 feet in the Laramie-Fox Hills aquifer. Limited connection exists among 

these deep aquifers and with the shallow alluvial aquifers associated with the South Platte River 

valley and its tributaries.

The STM site overlies the shallowest portions of the Denver, Arapahoe, and Laramie-Fox Hills 

aquifers. The NWTC site overlies the shallowest portions of the Arapahoe and Laramie-Fox Hills 

aquifers. The northern extent of the Dawson aquifer is located approximately twenty miles to the 

south and east of the STM site; consequently, wells drilled at the STM site and NWTC would not 

intersect the Dawson aquifer.

Because of the sensitive nature of the groundwater resource, NREL carefully evaluates all outdoor 

projects to eliminate potential impacts to groundwater quality. If any materials are used that pose a 
NREL Environmental Performance Report- 2009 Page 48

risk to groundwater, the laboratory typically insists that safeguards to protect groundwater be 

established. Safeguards include, but are not limited to, secondary containment for equipment with the 

potential to leak oil, double-walled tanks with leak detection for diesel fuel storage of NREL 

facilities’ emergency generators, and bermed areas to contain experimental materials.

In 1990, groundwater characterization began with the installation of a monitoring well network at the 

STM site. Eight wells were installed at the base of the mesa slope. Four upgradient wells were 

installed to investigate background water quality prior to its crossing NREL facility boundaries, and 

four wells were placed in a generally downgradient direction to verify that NREL activities had not 

adversely affected groundwater quality. Quarterly sampling was performed for five calendar quarters, 

followed by annual sampling for three years. No evidence of contamination was found. Groundwater 

quality at NREL was similar to other portions of the Denver Basin. In addition, routine follow-up 

sampling was done in 1997. Three of the initial eight wells were closed (in accordance with state 

requirements) due to construction activities in 1993, and a fourth was found to be inaccessible during 

the 1997 sampling, also due to construction activity in the area. Therefore, follow-up samples were 

only collected from four of the original monitoring wells: three upgradient wells and one 

downgradient of NREL development. No evidence of contamination was found in the 1997 

sampling.

In June 1998, a diesel leak to the environment from a failed check valve on the PDU emergency 

generator aboveground storage tank at the Alternative Fuels User Facility occurred. The majority of 

contaminated soil was excavated and removed from the site for disposal at a permitted landfill. Three 

groundwater monitoring wells were installed at the site in September 1998, one upgradient and two 

downgradient. No hydrocarbon contamination was detected in the groundwater during the initial 

sampling of the three wells, or during follow-up sampling conducted in March and September 1999, 

and March 2000. These three monitoring wells were closed in 2006 in accordance with state 

requirements.

The NWTC currently has no open or active groundwater wells. A water supply well once provided 

water to Building 251 when DOE’s Rocky Flats Field Office operated the site. In 1993, NREL 

collected samples from the well and the associated water distribution and treatment system as part of 

an evaluation of alternatives for water supply to the site. Based on the sampling results, it was 

determined that the maintenance and repairs required to make the existing well and treatment system 

effective were extensive, and there was an indication of the potential for trace organic compounds in 

the water. Therefore, when DOE's Golden Field Office assumed landlord responsibility for the site in 

1993, the connection between the building and the well was severed. The water supply well was 

plugged and abandoned in accordance with state regulations in 1996. Potable water is currently 

transported to the site, as described in Section 5.2 of this report. NREL has done no other 

groundwater sampling at the site. 

NREL has not conducted groundwater monitoring at its leased DWOP site, as there have been no 

activities that pose an unusual risk to groundwater quality. If NREL had reason to suspect a 

groundwater quality problem, the issue would be addressed with Denver West Management. DWOP 

management contracted with an engineering firm to conduct a groundwater monitoring study in 1988 

adjacent to the NREL-leased buildings. Two monitoring wells were drilled. There were no detections 

of significant levels of contaminants.

There have been no groundwater studies performed by NREL at either the JSF or the ReFuel Facility, 

as there have been no activities at these sites that pose an unusual risk to ground water. 
NREL Environmental Performance Report- 2009 Page 49

There is currently no ongoing routine groundwater monitoring program on any NREL site.

Groundwater sampling will be conducted if future activities pose a risk to the groundwater quality.

5.3.2 Permitting

All groundwater monitoring wells installed by NREL at the STM sites have been permitted with the 

Colorado Department of Natural Resources. 

5.3.3 2009 Activities

In 2009, there were no new groundwater-related activities.

5.4 Wastewater Discharge

5.4.1 Program Management 

Management in this area is consistent with NREL’s Waste Management and Minimization Program 

(6-2.8).

The majority of wastewater from NREL’s STM and DWOP facilities flows into the Pleasant View 

Water and Sanitation District’s system, and ultimately to Metropolitan Wastewater Reclamation 

District’s (Metro) treatment plant. There is a small septic system consisting of a tank and absorption 

field on the mesa top, serving the Solar Radiation Research Laboratory (SRRL), because there is no 

sewer line to the mesa top. Wastewater from the JSF and the ReFUEL facility also flows to Metro’s 

treatment plant. The NWTC is not connected to a sewer system, but has two septic systems that 

include tanks and absorption fields for the treatment of wastewater. 

It is NREL policy to comply with all requirements of Metro’s Pretreatment Program, including the 

list of general prohibitions that protect the collection and treatment systems. The list of prohibitions 

includes hazardous materials, highly viscous substances, radioactive material, excessive oil and 

grease, and similar substances that could cause material harm to the sanitary system. NREL staff is 

trained in this policy. In addition, NREL sites have design criteria for waste drains in lab areas to 

minimize the possibility of a hazardous material discharge. These criteria include measures such as 

secondary containment for any chemicals used near sinks in laboratory exhaust hoods, no floor drains 

in laboratory areas unless a specific need can be shown, and caps for any floor drains that are 

installed in lab areas. New research and operations activities as well as ongoing activities that 

undergo significant modifications are reviewed for their potential effect on wastewater character 

through NREL’s risk assessment process. 

5.4.2 Permitting 

No permitting for the majority of NREL’s wastewater discharges is required. NREL has no direct 

wastewater discharges to the environment at the DWOP, ReFUEL, or JSF, so no National Pollutant 

Discharge Elimination System (NPDES) permitting is necessary. NREL maintains three individual 

sewage disposal systems, two at the NWTC and one at the STM site. The remainder of NREL facility 

wastewater is discharged to Metro through the sanitary sewer system. NREL facilities are currently 

classified by Metro as non-industrial water users at these sites. As non-industrial users, NREL sites 

do not need a permit from Metro for sewer discharge, and monitoring for pollutants in wastewater is 

not required. 
NREL Environmental Performance Report- 2009 Page 50

NREL maintains septic permits from Jefferson County (an authority delegated to the counties under a 

State of Colorado program) for the NWTC’s IUF and Building 251 septic systems, as well as for the 

SRRL facility on the STM site mesa top. 

5.4.3 2009 Activities 

In 2009, there were no new wastewater discharge activities.

5.5 Surface Water Protection (Stormwater and Erosion Control)

5.5.1 Program Management

Management in this area is consistent with the following NREL Programs: Stormwater Pollution 

Prevention for Construction Activities at the STM (6-2.15), Stormwater Pollution Prevention for 

Construction Activities at the NWTC (6-2.16), and the Environmental Permitting and Notification 

(6-2.1).

5.5.1.1 Past Investigations

Historically, stormwater monitoring was conducted at the STM site during the summers of 1992 and 

1993 to characterize stormwater quality at NREL, confirm that NREL’s activities were not adversely 

impacting stormwater quality leaving the STM site, and provide a baseline against which future 

sampling could be compared.

Samples were collected at 3 locations: the western portion of the East Drainage, the Middle 

Drainage, and the Middle West Drainage located between the West and Middle Drainages. Water 

quality data indicate that NREL’s activities did not result in contamination of storm water runoff. For 

that reason, instream water quality samples of Lena Gulch, the receiving water to which stormwater 

from the STM site ultimately flows, were not collected. 

Lena Gulch is a tributary to Clear Creek, a major waterway in the west Denver region. The Urban 

Drainage and Flood Control District has mapped the 100-year floodplains of this region and 

determined that none of the NREL facilities encroach upon a floodplain.

In 1998, surface water samples were taken in two drainages at the NWTC in connection with 

NREL’s weed control efforts. No traces of the herbicide applied to weed-infested areas were detected 

in the water samples collected. Stormwater and surface water quality monitoring has not been 

conducted at NREL’s DWOP, JSF, and ReFuel sites.

5.5.1.2 Current Management Practices

Outdoor research projects and building construction are reviewed during the planning stages through 

NREL’s NEPA, risk assessment, and design review processes for potential impacts to stormwater 

and receiving waters. Measures to prevent impacts to stormwater are incorporated, as appropriate, 

into the design for each project. Potential control measures include secondary containment and 

bermed areas for chemical use and storage, covers or roofs to protect chemical use, and storage areas 

from precipitation and minimizing impervious areas to promote infiltration and decrease site runoff.

During construction, erosion and sediment controls are implemented according to the plans 

developed by contractors and reviewed by NREL EHS staff per NREL stormwater procedures.

Regular inspections by contractors and periodic site inspections by NREL staff are conducted to 

verify that the controls are functioning properly and to identify any required repairs. Written reports 
NREL Environmental Performance Report- 2009 Page 51

are prepared for all inspections; prompt corrective actions are required to correct any noncompliant 

conditions.

5.5.2 Permitting

Stormwater quality on federal facilities in Colorado is regulated by the U.S. EPA Region 8. To obtain 

coverage under U.S. EPA’s National Pollutant Discharge Elimination System (NPDES) General 

Construction Stormwater permit, NREL must submit a Notice of Intent (NOI) form. The site owner 

(DOE), site operator (Alliance for Sustainable Energy or previously, Midwest Research Institute), 

and construction subcontractors have filed NOIs with the EPA.

In 2009, NREL continued construction activities at the STM site for the Research Support Facility 

(RSF) and associated stormwater detention basin and access road covered by an NOI filed in 2008.

New NOIs were filed for the Integrated Bio-Refinery Facility (IBRF) and the RSF Infrastructure 

Project and at the NWTC a new NOI was filed for the Sun Edison 1MW photovoltaic array field.

5.5.3 2009 Activities

In addition to implementation of stormwater pollution prevention plans associated with permitted 

construction projects described above, NREL also applied numerous stormwater protection and 

erosion control practices and controls on small project sites for which General Construction 

Stormwater permits were not required. These were primarily located at the NWTC where the 

following activities occurred over the course of the year: placement of new data sheds and pads at 

Sites 3.3, 4.0 and 4.4, placement of a new trailer near Building 251, construction of foundations for 

wind turbines at Sites 1.2E, 3.3A, 3.3B and 3.3C, construction of foundations for meteorological 

towers at Site 3.3, and construction of a hydrogen vehicle fueling island at the DERTF.

5.6 Waste Management

5.6.1 Program Management 

Management in this area is consistent with the following NREL Programs: Waste Management and 

Minimization (6-2.8) and Environmental Permitting and Notification (6-2.1). 

Hazardous wastes are handled and disposed of according to the Resource Conservation and Recovery 

Act (RCRA) and the Colorado Hazardous Waste Act. NREL’s waste primarily consists of a broad 

range of hazardous laboratory chemicals in small quantities. Wastes in solid or liquid form are 

collected in each laboratory or at each experiment site and prepared for off-site disposal by the 

NREL EHS personnel. 

Hazardous waste is transported to EPA-permitted facilities for treatment and disposal. In addition, 

NREL has a conservative waste management policy where materials that are not regulated by RCRA, 

yet pose a potential hazard, are collected and disposed of as non-hazardous materials at RCRApermitted disposal facilities. This category includes nanomaterial-bearing wastes, which were added 

to the waste procedure in 2008 and management of these materials continued into 2009.

NREL facilities also generate small quantities of low-level radioactive wastes. This waste normally 

consists of personal protective equipment, disposable labware, scintillation fluids, and water-based 

liquids. Radioactive waste is shipped off-site for disposal on an as-needed basis. 
NREL Environmental Performance Report- 2009 Page 52

5.6.2 Permitting 

NREL has five separate sites that have the potential to produce quantities of hazardous waste in 

various amounts. Each of the five sites has a RCRA waste generator identification number issued by 

the State of Colorado. The STM location is classified as a "small quantity generator," generating less 

than 1,000 kg of waste per month. The other four sites–the Joyce Street Facility, the National Wind 

Technology Center, the Denver West Office Park, and the ReFUEL facility–are classified as 

"conditionally exempt small quantity generators," generating less than 100 kg of waste per month. 

5.6.3 2009 Activities 

In CY2009, NREL shipped 15,943 pounds (7,246 kg) of hazardous waste, 2,348 pounds (1,067 kg) 

of non-RCRA regulated waste, and 15,141 pounds (6,882 kg) of universal waste for disposal and 

recycling from all five sites combined. Universal waste includes batteries, fluorescent light bulbs, 

and electronic equipment. In CY2009, there was a 45% reduction in the amount of hazardous waste 

shipped from the CY2008 levels. 

In 2009, no radioactive waste was shipped for off-site disposal. However, in September 2008, work 

began in the FTLB using phosphorus-32, a radioactive isotope. Waste generated by these activities 

was collected in May and November 2009. Information regarding the types and quantities of 

radioactive materials used at NREL facilities is detailed in Section 5.16. 

In 2007, a number of national laboratories, including NREL, developed an approach for the 

management of nanomaterials at DOE facilities. In 2008, DOE directed the laboratories to implement 

control programs at the laboratories for nanomaterials and for wastes that contain these substances.

NREL developed a program that instituted administrative and engineering controls on the use of 

nanomaterials, the creation of nanoparticles, and the management of nanomaterial-bearing wastes.

Because there is some uncertainty surrounding the risk of these substances to human health and the 

environment, DOE and the national laboratories have taken a conservative approach to the use and 

disposal of nanomaterials. In CY2009, NREL continued to implement the management procedures 

for nanomaterial-bearing waste as described in NREL’s updated Waste Management and 

Minimization procedure. This material is collected and stored as hazardous waste, and ultimately sent 

to licensed treatment storage and disposal facilities (TSDFs) for disposal.

In CY2008, in anticipation of a rise in the amount of generated waste due to laboratory growth, 

NREL increased the waste management training requirements to once per year, implemented 

documented weekly inspections of all waste collection areas, and began regularly shipping waste offsite every 90 days. The increase training requirements and the weekly inspections will satisfy the 

regulatory requirements anticipated when waste production increases to above the large quantity 

generator threshold. Waste inspectors are selected for each laboratory in which waste is generated; 

these areas are designated Satellite Accumulation Areas. The inspector is responsible for conducting 

weekly inspections and documenting them on forms submitted to the EHS organization. These 

practices continued throughout CY2009.

5.7 Storage Tanks (Underground and Aboveground) 

5.7.1 Program Management 

Management in this area is consistent with the following NREL programs: Aboveground Storage 

Tank Management (6-2.7) and Spill Prevention Control and Countermeasures for the South Table 

Mountain Site (6-2.10). NREL does not have any underground tanks with hazardous materials. 
NREL Environmental Performance Report- 2009 Page 53

NREL facilities store diesel fuel for emergency generators and ethanol from research activities in 

aboveground storage tanks. NREL's tank management program focuses on proper tank design, 

operation, and inspection to protect against spills and leaks. The program is designed to meet 

regulatory requirements and is more stringent in some aspects than regulations require. 

Several important mechanical and procedural safeguards have been incorporated into NREL’s tank 

management program to prevent any accidental releases of diesel fuel from the storage tanks. 

Mechanical safeguards include overfill and spill protection, double wall tanks for diesel fuel 

equipped with sensors that result in an alarm if the inner tank wall is leaking, and a exterior concrete 

containment structure for the ethanol storage tank. Procedural safeguards include written operating 

procedures and tank filling procedures. All tanks larger than 110 gallons are visually inspected at 

least once per month. 

Due to the quantity of fuels stored on the STM, NWTC, and ReFUEL sites, a Spill Prevention 

Control and Countermeasures Plan is required for each of these locations. This plan describes the 

topography of each site and neighboring areas, and outlines the steps necessary to mitigate any spills 

or leaks of diesel fuel. To date, NREL has not had any off-site impacts related to tank activities. 

5.7.2 Permitting 

Aboveground tanks larger than 660 gallons require annual registration with the State of Colorado. 

Currently, only two tanks meet the registration threshold: the SERF emergency generator diesel 

storage tank and the Process Demonstration Unit (PDU) ethanol storage tank at the AFUF. Both are 

located on the STM site. 

5.7.3 2009 Activities 

An inspection of NREL’s regulated aboveground storage tanks (ASTs) was conducted by the 

Colorado Department of Labor and Employment’s Division of Oil and Public Safety in 2009. The 

inspector found no deficiencies. No spills or releases from NREL’s ASTs occurred during 2009.

5.8 Hazardous Materials Management 

5.8.1 Program Management 

Management in this area is consistent with the following NREL programs: Chemical Safety Program 

(6-4.6) and Asbestos Management Program (6-4.18).

No active or abandoned hazardous waste sites have been identified on any of the laboratory sites. 

Therefore, many sections of the Comprehensive Environmental Response, Compensation, and 

Liability Act do not apply to NREL facilities. 

NREL facilities are subject to the EPCRA Section 302 emergency reporting provisions which require 

a facility to notify the State Emergency Response Commission (SERC) if any extremely hazardous 

substances in the facility's inventory are stored in quantities greater than prescribed threshold 

planning quantities (TPQ). NREL facilities first became subject to planning and notification 

requirements in 1988.

EPCRA Section 304 requires facilities to immediately notify the Local Emergency Planning 

Committee (LEPC) if there is an accidental spill or release of more than the predetermined RQ. 

In accordance with Section 311 and 312 of EPCRA, NREL provides Material Safety Data Sheets 

(MSDS) for chemicals that are stored on-site in quantities greater than TPQs, and provides inventory 
NREL Environmental Performance Report- 2009 Page 54

reporting for these same chemicals in the form of Tier I or Tier II reports to emergency planning and 

response groups. 

When requested, NREL provides additional emergency response and reporting information to the 

Jefferson County LEPC, the SERC, the West Metro Fire Rescue District (West Metro), and the 

Rocky Mountain Fire Protection District. The Jefferson County LEPC uses hazard categories and 

threshold reporting quantities as defined by the Uniform Fire Code rather than those specified in 

SARA Title III, resulting in a larger number of individual hazard categories and lower reporting 

thresholds. NREL has been represented in the LEPC since its inception and is actively involved in 

the emergency planning concepts of SARA Title III with two acting members on the Jefferson 

County LEPC.

The laboratory is also subject to reporting requirements in the event of a release of an RQ of any 

hazardous substance listed by EPCRA. EPCRA Section 313 requires that a toxic chemical release 

inventory report (Form R) be filed with the EPA for any chemical that is manufactured, processed, or 

otherwise used in quantities exceeding TPQs. Although NREL is not a manufacturing facility and 

does not fall within any of the standard industrial classification (SIC) codes for which Section 313 

reporting is required, EO 12856 requires all federal facilities to file a report, if applicable, regardless 

of SIC code. NREL has not had any releases of a Section 313 listed material above the RQ, so NREL

has not had to file a Form R with EPA.

Section 112r of the Clean Air Act regulates numerous toxic and flammable substances, and, similar 

to EPCRA, establishes threshold quantities for these materials. Unlike EPCRA, however, the Section 

112r threshold quantity applies to the amount of substance in a single process, not the entire facility. 

To date, NREL has not met the thresholds that trigger applicability of Section 112r. 

NREL has a laboratory-wide chemical management system (CMS) that serves as a centralized 

chemical inventory as well as a tool for managing and reporting on chemicals used at the laboratory. 

Using an electronic bar-coding system, the CMS tracks chemicals from the point of receipt through 

end-use and disposal. The system also contains technical data and reporting information for many of 

the chemicals in the CMS database. Key functions of the system include: 

Providing current inventories by room, building, and/or site

Improving research efficiency and minimizing hazardous waste generation by allowing staff 

to determine if needed chemicals are already available on-site prior to making chemical 

purchases

Providing quick access to chemical inventories and hazard information during emergency 

responses

Facilitating accurate and efficient reporting to external agencies (e.g., fire districts, LEPC, 

EPA, and DOE). 

In 2009, the CMS system was upgraded to new software and hardware to better serve these 

functions. The EHS organization coordinates the operation of the CMS, but other organizations are 

critical to keeping the system information up-to-date. Shipping and Receiving is responsible for 
NREL Environmental Performance Report- 2009 Page 55

chemical labeling and data entry, Information Services provides support for the dedicated server that 

hosts the CMS, and researchers are responsible for reporting the transfer and disposal of chemicals. 

Asbestos surveys have been conducted in a number of NREL facilities: the Joyce Street Facility, 

Building 251 at the NWTC, Building 16, the STM Site, the AFUF (only older areas of the building), 

the FTLB, and the SRRL. No asbestos was found at the Joyce Street Facility and the AFUF. The 

other facilities have limited amounts of asbestos-containing material in areas such as floor tile, lab 

countertops, caulking and sealants, and roofing materials. Asbestos-containing materials are left 

undisturbed whenever possible. If renovation is planned that will disturb asbestos-containing 

material, then certified asbestos removal contractors are used and strict asbestos removal procedures 

are followed. An Asbestos Management Program is in effect for all NREL facilities. 

5.8.2 Permitting 

NREL obtains annual Hazardous Material Permits from West Metro for the STM and DWOP sites. 

The permits are required by West Metro. NREL obtains permits for a total of six buildings where 

hazardous materials are stored and/or used. Prior to issuing the permits, a representative from West 

Metro conducts a walk-through inspection of the entire STM site and DWOP. 

The ReFUEL facility is within the jurisdiction of the City of Denver Fire Department (DFD) and is 

subject to the DFD Hazardous Materials Information System (HMIS) requirements. The ReFUEL 

Facility’s inventory of listed materials, including various fuels such as biodiesel, must be reported to 

the DFD annually. DFD inspects the facility and issues a Hazardous Materials Permit.

5.8.3 2009 Activities 

West Metro conducted a walk-through inspection of NREL’s STM and DWOP facilities in the 

summer of 2009. Annual Hazardous Materials Permits for the six buildings were issued following the 

inspection. The CMS was used to provide complete chemical inventories for each facility as part of 

the permit application process. 

Similarly, the CMS provided inventory information to meet the DFD’s HMIS requirements. The 

ReFUEL Facility’s Hazardous Material Permit was renewed by the DFD in July 2009. Finally, the 

CMS is used to determine if the laboratory had quantities of extremely hazardous substances and 

other reportable materials that would require the submission of a Tier II report to the LEPC. In 2009, 

NREL had no extremely hazardous substances that exceed the TPQs.

5.9 Pollution Prevention and Sustainability

5.9.1 Program Management

Management in this area is consistent with the following NREL programs: Environmental 

Management (6-2), Sustainable NREL (2-7), and NREL’s EMS description. Most of the activities 

conducted by the Sustainable NREL program are in the following areas:

Waste minimization, recycling, and green purchasing

Transportation

Energy

Renewable energy

GHG emissions

Water conservation
NREL Environmental Performance Report- 2009 Page 56

Sustainable building design

Technical assistance and outreach.

5.9.2 Permitting

NREL has no permit requirements applicable to Pollution Prevention and sustainability management. 

As a DOE facility, NREL does set objectives to meet goals established by federal executive orders 

(e.g., EO 13423) and DOE orders.

5.9.3 2009 Activities

The Sustainable NREL Program publishes an annual report that provides the details of 

accomplishments in the areas of activities listed above. Because the Sustainable NREL Program is 

closely linked to the Environmental Management System, the program accomplishments of these 

efforts are covered in Section 4 of this report.

5.10 Vegetation Management 

5.10.1 Program Management 

Management in this area is consistent with NREL’s Weed Management Programs for the STM and 

NWTC (6-2.12) and the Sustainable Landscape Design and Management Program (6-2.19). 

NREL’s approach to vegetation management is to conserve existing ecosystems in their natural state 

as much as possible. There is some landscaping using non-native drought-tolerant species adjacent to 

some of the buildings, and even a few areas of bluegrass at the STM site. However, the native 

vegetation and natural character of the landscape is maintained over the majority of the site. 

Revegetation of areas to be left in their natural state following disturbance from construction or other 

outdoor activities is conducted using a native seed mix of grasses and forbs. These mixes are sitespecific and are composed predominantly of native species that were originally present on the site 

before disturbance. Seed mix and revegetation procedures are outlined in NREL’s Stormwater 

Pollution Prevention Programs for the STM and NWTC Sites. The use of native species is required at 

both the STM and NWTC whenever possible. When feasible, high-water demand species like 

Kentucky bluegrass are replaced with drought-tolerant native species. The most recent vegetation 

survey of the STM was conducted between June 2001 and May 2002. Five general habitats were 

described on the STM site, comprising seven plant communities (Plantae Consulting Services, 2002). 

No rare or imperiled plant species were found on the site. Areas of mixed foothills shrublands (also 

called tall upland shrubland) were identified on top of the mesa within the conservation easement 

area. This natural community is listed as rare and imperiled by the Colorado Natural Heritage 

Program. No development will occur in the conservation easement area. 

In Colorado, the Department of Agriculture Commissioner, in consultation with the state noxious 

weed advisory committee, local governments, and other interested parties, develops and implements 

state noxious weed management plans for three categories of weed species. Class A plants are 

targeted for eradication while Class B species are subject to management plans designed to stop the 

continued spread of these species. Class C species are subject to plans designed to support the efforts 

of local governing bodies to facilitate more effective integrated weed management on private and 

public lands. The goal of such plans will not be to stop the continued spread of these species but to 

provide additional education, research, and biological control resources to jurisdictions that choose to 

require management of List C species. Of the noxious weed species that have been identified on the 
NREL Environmental Performance Report- 2009 Page 57

STM site, three—Canada thistle, diffuse knapweed, and musk thistle—are Class B species and one, 

field bindweed, is on the Class C list.

A three-season vegetation survey of the NWTC site was performed between August 1999 and 

August 2000. The survey defined five general habitats on the NWTC site, comprising nine plant 

communities and 271 vascular plant species (Plantae Consulting Services, 2000). No rare or 

imperiled plant species were found on the site. However, the survey identified a small area of xeric 

tallgrass prairie (defined as mesic mixed grassland in this study) located in the southwest corner of 

the NWTC. This natural community is listed as rare and imperiled by the Colorado Natural Heritage 

Program. This listing implies no legal designation or regulatory enforcement. It is so designated 

primarily for management purposes. This area of the NWTC is not impacted by research or 

construction activities on the site. 

Of the weed species identified at the NWTC site, four—Canada thistle, diffuse knapweed, musk 

thistle, and leafy spurge—are Class B species and one, field bindweed, is on the Class C list. Based 

on the survey, recommendations were made to continue using a comprehensive weed management 

program, founded on an integrated pest management (IPM) philosophy. 

The survey showed the native seed mix used for revegetation at the NWTC to be very successful in 

many areas of the site. NREL is continuing the use of this seed mix for revegetation at the NWTC. 

Weed control efforts have been ongoing since 1997 at the NWTC and 1998 at the STM site. NREL 

uses an IPM approach that incorporates various types of weed control methods. Some of these 

include mechanical practices (e.g., mowing), cultural (e.g., reclamation of disturbed areas), 

prevention (e.g., limiting or eliminating driving of vehicles off established roadways), and herbicide 

treatment. The effectiveness of control methods is periodically assessed. The use of multiple 

strategies for control has been successful in significantly reducing populations of diffuse knapweed 

and Canada thistle on the sites. The key aspect of the weed control program is to maintain flexibility 

to respond to the changes in weed populations from year to year. 

In 1998, aerial herbicide application of Tordon 22K was conducted using helicopter application over 

about 200 acres of the NWTC to target diffuse knapweed. It was very effective in controlling the 

weed, and healthy stands of native grasses have proliferated with the decrease in weed competition. 

Since that time, infested areas of the NWTC have been treated with ground-applied herbicide. 

Weed infestations at the STM site are much less severe than at the NWTC. Limited ground 

application of herbicides has been conducted at the STM since 1998. 

NREL promotes the sustainable management of its government-owned land by practicing 

environmentally sound, cost-effective landscaping practices. These practices reduce adverse impacts 

to the natural environment while providing essential shade and cooling for indoor and outdoor 

spaces, and a more aesthetically appealing appearance for the sites. This commitment is implemented 

by a sustainable landscape design and management program. 

5.10.2 Permitting 

There is no permitting applicable to vegetation management, although there is a state weed law that 

requires property owners to control certain species of invasive weeds (e.g., diffuse knapweed). For 

application of certain types of herbicides designated as ―restricted use‖ by the EPA, a certified 

applicator must be used. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) has a 
NREL Environmental Performance Report- 2009 Page 58

provision that makes it illegal to use a pesticide ―in a manner inconsistent with its labeling.‖ In other 

words, the label is the law. NREL strictly follows all pesticide label requirements.

5.10.3 2009 Activities 

NREL routinely practices IPM using various weed control methods, as described in the previous 

section. These are implemented during the normal course of site operation. In addition to the 

reclamation, off-road driving restrictions, and other weed control methods, ground applications of 

herbicides occurred at the NWTC in the spring of 2009. Very limited herbicide application was 

conducted on the STM site in the spring of 2009, focusing primarily on areas adjacent to roadways 

and buildings. The spraying was performed using a four-wheel drive vehicle. Primary target weeds 

were diffuse knapweed, leafy spurge, Canada thistle, common teasel, and hoary cress at the NWTC. 

At the STM, target weeds were mainly diffuse knapweed and Canada thistle with small areas of 

Dalmatian toadflax. 

In 2006, the weed management plans for the NWTC and STM were consolidated into an integrated 

weed management plan. Weed management activities used in 2009 were consistent with the 

integrated plan. 

A master plant list for NREL was compiled in 2007. This list is based on information gathered during 

comprehensive vegetation surveys of the STM and NWTC completed in FY 2000-02 by Plantae 

Consulting Services. No formal field work has been completed since the FY 2002 survey, but the list 

is updated as NREL EHS staff becomes aware of species not on the list (see Appendix C). However, 

planning activities for FY 2010, which began in 2009, included conducting a formal vegetation 

survey at both the South Table Mountain campus and the National Wind Technology Center.

Contractor selection is scheduled for early 2010.

5.11 Wildlife 

5.11.1 Program Management 

Wildlife habitat at the STM site is primarily grasslands, shrublands, and wetlands, while habitat at 

the NWTC is comprised of grasslands, woodlands, shrublands, and wetlands. Both sites provide 

vegetation types for a variety of wildlife species including birds, mammals, reptiles, and amphibians. 

The variety of vegetation types attracts species that may use the site as year-round habitat, for 

breeding only, during migration, or as winter habitat. Wildlife surveys were conducted on the STM 

site in 1987 and 2005, with follow-up verification surveys conducted in 1998 and 1999. Vegetation 

surveys were conducted at both the NWTC and STM, in 1999, and 2001, respectively.

5.11.2 NWTC Site 

The NWTC site is located in the transition zone between the Great Plains and the Rocky Mountains, 

resulting in habitat that contains elements from both mountain and prairie ecosystems. The DOE 

prepared a biological characterization inventory for the adjoining Rocky Flats site, including the 

NWTC, in 1992. At that time, 11 mammals and 8 species of reptiles or amphibians were 

documented. Representative species currently using the site include deer mouse, prairie vole, desert 

cottontail, coyote, mule deer, prairie rattlesnake, bullsnake, plains garter snake, and tiger salamander.

Following the 1992 inventory, field surveys of avian use patterns at the NWTC were conducted in 

1994 and 1995 to identify potential impacts of wind-turbine research on birds. Several species of 

raptors, including red-tailed hawk, American kestrel, and great-horned owl, were noted on the site, 
NREL Environmental Performance Report- 2009 Page 59

primarily resting and hunting, although a pair of kestrels 

were found nesting during the spring. Birds of prey of 

concern, such as eagles, generally fly in excess of 152 

meters (500 ft.) over the site. No significant impacts to the 

birds from NREL activities were found during these 

surveys. 

 

 Figure 9. Sandhill Cranes over the NWTC

In early 2001, a year-long monitoring project for birds and bats was initiated at the NWTC. 

Standardized plot surveys were conducted to document the occurrence of songbirds and raptors on 

the site and adjacent undeveloped areas. This work also included systematic searches of turbines and 

meteorological towers to document avian mortality. The study was completed in July 2002. Notable 

findings of the study were as follows (Schmidt, E., et al., 2003): 

Abundances of individual raptor species on the NWTC site were similar to surrounding areas. 

However, the average number of species detected per count at the NWTC was nearly double 

that of surrounding areas in winter, the season when raptors are most abundant in the region. 

This difference is likely attributable to increased availability of perches at the site. Raptors 

flew and perched higher at the NWTC than in adjacent areas, again probably related to the 

wind turbines and other structures at the site. 

46 bird species were counted on grassland plots during this study. Only 1 differed in 

abundance between the NWTC and adjacent areas; the horned lark was about 16 times more 

common off site. This difference is attributable to cattle on Boulder Open Space, creating 

low-stature grasslands preferred by this species. 

Bird abundance and variety on the undeveloped southern portion of the NWTC site were 

generally similar to the developed areas, except for the relative scarcity of raptors on the 

undeveloped site, which probably was due to a lack of perches. 

The NWTC does not support a large diversity or abundance of bat species (possibly six 

species of bats use the site), but an area on the northwest side of the site, with trees close to a 

rocky outcrop, provides foraging and potential roosting habitat. 

No raptor carcasses were found during the 12-month survey of the NWTC except one 

American kestrel that had died before the study started. Bird mortality associated with the 

site appears to be minimal. Extrapolating from four passerine (songbird) carcasses found 

during the searches, estimated annual bird mortality attributable to NWTC activities was 24 

individuals, all songbirds (Passeriformes). Most of these deaths were probably the result of 

collisions with support wires for the meteorological towers rather than the turbines 

themselves. No evidence was found of bat fatalities at the site. 

5.11.3 STM Site 

Similar to the NWTC, the STM site is located in the transition zone between the Great Plains and the 

Rocky Mountains, resulting in habitat that contains elements from both mountain and prairie 

ecosystems. The most recent site-wide wildlife survey of the STM site began in April 2004 and was 

completed in June 2005. The objectives of the survey were to update existing data in light of 

expanded development of both the site and the surrounding area, and to develop best management 

practices for future construction projects to maximize protection for site wildlife. 
NREL Environmental Performance Report- 2009 Page 60

The survey included large and small mammals, predators, migratory 

birds and raptors, upland game birds, and invertebrates identified on 

an opportunistic basis (i.e., only as they are found during other 

surveys). A list of species observed at NREL is found in Appendix 

B; it includes the species observed during the year-long 

STM wildlife survey. 

5.11.4 Permitting 

Scientific collection licenses must be obtained from the Colorado 

Division of Wildlife for the small mammal trapping portion of the 

wildlife surveys. NREL has no other permitting requirements for 

this area of environmental management. 

5.11.5 2009 Activities 

In compliance with the Migratory Bird Treaty Act, surveys for 

ground-nesting birds were completed prior to activities that could adversely affect these species. 

Surveys were conducted during the nesting season, from mid-April through mid-September. If an 

active nest was found, a buffer zone was set up around the nest to avoid impacts to nests during site 

activities. 

5.11.5.1 Migratory Birds and Raptors 

Many species of migratory birds were observed on the STM site, with many of these species 

potentially nesting on site. Additionally, the STM site provides important migration and winter 

habitat for migratory birds. For example, American tree sparrows are only observed on site during 

the winter and northern harriers have been observed hunting on site only in the fall and winter. 

Several species were only observed during the fall, including blue jay, downy woodpecker, redbreasted nuthatch, loggerhead shrike, and rock wren, suggesting that these species may use the STM 

site as a stopover during migration. Habitat for migrating birds is important, as some of these species 

may migrate as far south as Central and South America. 

Several species of raptors were observed at the STM site and, two species were observed by both 

studies (1987 and 2004-2005) nesting on site; the red-tailed hawk and the American kestrel. Both of 

these species were observed hunting onsite during the 2004-2005 surveys, in 

addition to the Cooper’s hawk, which is 

known to nest along nearby Clear Creek. 

The NREL STM site provides habitat and 

a prey base of small birds and small 

mammals for these raptor species. Species 

such as the Swainson’s hawk migrate 

thousands of miles each year to winter in 

Argentina, and return to the western 

United States and Canada to breed. Areas 

such as the STM site may provide a prey 

source for the Swainson’s hawk and other 

species during migration. 

Figure11. Cedar Waxwing at Building 7 in DWOP

Figure 10. Western Kingbirds nesting 

in an old shoe
NREL Environmental Performance Report- 2009 Page 61

5.11.5.2 Summary Of 2009 Bird Surveys 

2009 Bird Surveys–STM 

Several ground-nesting bird surveys were conducted on the mesa top portion of the STM in advance 

of planned construction activities associated with the on-going construction of the Research Support 

Facility and new infrastructure projects. No active nests were found during any of these surveys, and 

construction activities were allowed to proceed.

2009 Bird Surveys–NWTC

In 2009, ground-nesting bird surveys were done at the NWTC in areas slated for installation of new 

wind turbines. Construction activities were restricted in one area in the vicinity of the General 

Electric turbine after a fledgling vesper sparrow was found during one survey. Surveys were repeated 

until no young were found or adult defense behavior observed.

5.11.5.3 Large Mammals 

Mule deer at the STM site have been observed in all habitat types. Mule deer were often observed in 

the amphitheater drainage or in the tall shrubland on the slope. When approached on the mesa top, 

the mule deer tended to move away from the disturbance and into the amphitheater drainage. 

The tall shrubland vegetation type may provide important hiding cover for this species. Spring pellet 

group surveys resulted in nearly double the amount of pellet groups and plots of the pellet groups 

were observed in than fall surveys. This may suggest that winter use of the STM site by deer may be 

higher than summer use or that deer utilize different habitats on site for these periods as affected by 

the availability of habitats and the location of survey plots, although the single year of data is not 

sufficient to draw conclusions regarding seasonal variation. 

5.11.5.4 Predators 

Coyotes are one of the most widespread and adaptable carnivores in North America and occur at all 

elevation levels and in all ecosystems in Colorado (Fitzgerald, et al. 1994). Lagomorphs (rabbits) and 

rodents are an important part of the coyote’s diet, both of which are abundant on the STM site. 

Evidence of predation on cottontail rabbits (i.e., entrails and fur) was observed during site visits. 

Coyotes may breed on the STM site as two potential dens were observed in two of the site drainages. 

5.11.5.5 Small Mammals 

The deer mouse is the widest ranging and 

most common small mammal in North 

America (Fitzgerald, et al. 1994), and 

based on the 1987 and 2004-2005 survey 

data, it is also the most common small 

mammal on the NREL STM site. Deer 

mice can occur anyplace where cover 

occurs (Fitzgerald et al. 1994) and were 

observed in the four vegetation types 

sampled on the STM site. This species is a 

generalist and is known to exploit 

disturbed habitats. 

Figure12. Young Cottontail Rabbit at STM

Mexican woodrats and prairie voles have more restricted ranges at the STM site. Mexican woodrats 

are associated with rocky slopes and do not build dens away from rocky areas (Fitzgerald et al. 
NREL Environmental Performance Report- 2009 Page 62

1994); this habitat is limited at the STM site. Prairie voles are adapted to grasslands, constructing 

burrows and runway systems throughout the grassland, essentially limiting this species to the short 

grass and mixed grass vegetation types on the STM site. 

In November 2008, NREL developed a plan for the environmentally responsible removal of an 

estimated 50 prairie dogs from the western portion of the NWTC. A 1MW photovoltaic array is 

planned for the area currently colonized by the prairie dogs necessitating the removal. Biologists at 

NREL determined that the most cost-effective and environmentally responsible procedure included 

on-site re-location of the prairie dog colony to the northwest corner of the NWTC within one of the 

designated conservation management areas. By the end of 2008, a capture/re-location company was 

awarded a contract, and monitoring of current conditions was completed, and trenching in the relocation area was initiated. This project continued into CY2009 with the successful re-location of the 

colony. The colony was relocated to the northwest corner of the NWTC. Unfortunately, the colony 

was stricken by plague late in the year and all but a few individuals perished.

5.11.5.6 Reptiles/Amphibians 

Several rattlesnakes were observed on the STM site, more often in rocky areas, but also in the 

grassland. A rattlesnake den may be present in the rocks near the top of the mesa slope north of the 

Visitors Center (near E-2-3) as four rattlesnakes were observed within a few feet of each other since 

2007, one in the open and three in a rock crevice. Hibernation generally occurs in rock outcrops, with 

this species usually active from mid-April through late-September (Hammerson 1999). 

Although only four species of reptiles and one species of amphibian were opportunistically observed 

on the STM site, no specific survey methods were employed to identify or count these groups of 

wildlife. 

To avoid or minimize disturbance to wildlife species on site, site-wide BMPs were developed as a 

result of this survey for consideration during ongoing normal site operations and future construction 

projects. The BMPs address migratory birds and raptors, mammals, all wildlife, and general site 

operations. They will be applied as appropriate to site activities and future site development.

5.11.5.7 Planning Activities

Planning began in 2009 for FY2010 wildlife surveys at both the STM and MWTC. EHS began 

developing a scope of work that will generate results comparable to the previous wildlife surveys at 

these sites. In addition to the wildlife surveys, EHS began work on an avian monitoring project at the 

NWTC associated with the installation of the Siemens turbine. A contractor was hired to develop the 

methodology for an avian monitoring project at the NWTC. The plan was completed in December 

2009 for implementation in 2010. The plan has four major components: 1. Fixed-point monitoring; 2. 

Transect surveys; 3. Mortality Surveys; and 4. Raptor Monitoring during spring migration.

5.12 Endangered Species/Species of Concern 

5.12.1 Program Management 

The Endangered Species Act provides for the designation and protection of wildlife, fish, and plant 

species that are in danger of extinction, and preserves the ecosystems on which these species depend. 

For the purposes of site wildlife surveys, a species of concern is defined as one protected under 

federal statutes, including the Endangered Species Act of 1973, as amended, the Bald Eagle 

Protection Act of 1940, as amended, and the Colorado Division of Wildlife list of endangered, 
NREL Environmental Performance Report- 2009 Page 63

threatened, and wildlife species of concern. Federal agencies are also required to abide by the 

Migratory Bird Treaty Act of 1918, as amended, but for this report, these species are not included as 

species of concern. For plant surveys, the Colorado Natural Heritage Program designation is also 

considered. Although this listing of rare species is not regulatory in nature, NREL uses it for 

management purposes.

The U.S. Fish and Wildlife Service has identified eight species listed in accordance with the 

Endangered Species Act as threatened, endangered, or a candidate for listing, that could potentially 

occur within the STM site project area. Of the State of Colorado’s species of concern, eight species 

may potentially occur at the STM site. None of these were observed during any of the site surveys.

However, based on existing habitat, four species could potentially be found at the site: American 

peregrine falcon, bald eagle, ferruginous hawk, and black-tailed prairie dog. Although a similar 

comparison of existing habitat at the NWTC to listed species has not been done to date, there is a 

colony of black-tailed prairie dogs present at the NWTC. The colony has been relocated to the 

northwestern portion of the site, in one of the designated conservation management areas.

The vegetation survey at NWTC, conducted between August 1999 and August 2000, identified a 

small area of xeric tallgrass (defined in the survey as mesic mixed grassland) prairie located in the 

southwest corner of the NWTC site. This natural community is listed as rare and imperiled by the 

Colorado Natural Heritage Program. This listing implies no legal designation, but is made primarily 

for management planning purposes. This xeric tallgrass prairie area has been designated by NREL as 

a conservation management area. Most of the conservation management areas on the NWTC are 

formally designated as areas on which building will not occur. However, as the xeric tallgrass prairie 

is in the active turbine testing area, it is not reasonable to preclude all development on portions of the 

site inhabited by this plant community. However, to the greatest extent possible, disturbance will be 

minimized on this biome. 

The STM site vegetation survey completed in May 2002 found no rare or imperiled plant species on 

the site, but areas of mixed foothills shrublands (also called tall upland shrubland) were identified 

along the top of the mesa within the conservation easement area. That natural community is listed as 

rare and imperiled by the Colorado Natural Heritage program. It is within a designated conservation 

easement area where no development will occur except trails being established by Jefferson County 

Open Space (see Section 6.0 for a trails discussion). 

As reported in Section 5.11.3, a site-wide wildlife survey of the STM site has recently been 

completed. No species observed on the STM site during the 1987 or the 2004-2005 wildlife surveys 

were present on either agency’s list. However, golden eagles were incidentally observed on the STM 

site (outside of raptor surveys) and are protected under the Bald and Golden Eagle Protection Act. 

Golden eagles were observed flying over the site and may use the site for hunting. No golden eagle 

nests or nesting activities were observed on the STM site. 

5.12.2 Permitting 

NREL has no permitting requirements for this area of environmental management. 

5.12.3 2009 Activities 

In 2009, the presence of the non-native Eurasian Collared Dove continued at NREL’s STM. This 

invasive species, first spotted at STM in 2006 as a new avian species, had just begun to inhabit the
NREL Environmental Performance Report- 2009 Page 64

Denver area at that time. The Colorado Division of Wildlife considers this species to be a threat to 

native avian species.

5.13 Wetlands/Floodplains

Management in this area is consistent with the following NREL Programs: Stormwater Pollution 

Prevention for Construction Activities at the STM (6-2.15), Stormwater Pollution Prevention for 

Construction Activities at the NWTC (6-2.16), and the Environmental Permitting and Notification 

(6-2.1).

Wetlands are defined by the USEPA and the Army Corps of Engineers (USACE) as areas that are 

inundated or saturated by surface or ground water at a frequency and duration sufficient to support, 

and that under normal circumstances do support, a prevalence of vegetation typically adapted for life 

in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.

Wetlands became regulated in 1972 when, under the Clean Water Act, the definition of waters of the 

U.S. was expanded from only those waters capable of supporting interstate or foreign commerce as 

defined under the Rivers and Harbors Act of 1899, to waters that also include tributaries to navigable 

waters, interstate wetlands, wetlands which could affect interstate or foreign commerce, and wetlands 

adjacent to other waters of the U.S.

Wetlands that meet hydric soils, vegetation and hydrologic criteria, are protected under the Clean 

Water Act Section 404, which is administered by the USACE, with program oversight provided by 

the USEPA. Areas that do not meet the criteria established by the USACE may perform wetland 

functions and serve as valuable ecologic components, but do not fall within the jurisdiction of the 

USACE and are therefore not protected or regulated under Section 404 of the Clean Water Act.

In early 2009, the USACE was invited to the STM site to determine whether the observed wetlands 

and drainages that cross the STM site are considered jurisdictional and therefore regulated by the 

USACE. The following six drainages were identified:

East Drainage (east of the Visitors Center)

Middle Drainage (originating upstream of the amphitheater and flowing between the FTLB 

and the SERF)

Middle West Drainage (above the Thermal Test Facility (TTF)

West Drainage (near the west entrance gate)

Jefferson County Easement Drainage (south of Denver West Parkway and east of the ―lower 

25‖)

Roadside drainages and trickle channel drainages (constructed drainages generally on the 

north side of Denver West Parkway).

Following their site visit, the USACE issued a letter stating that all drainages examined were 

considered upland swales vegetated with upland vegetation and are, consequently, not 

regulated/protected by the USACE. They provided a jurisdictional determination (JD) documenting 

their finding. The USACE JD, valid for five years (through April 27, 2014), enables NREL to 

perform work in the upland swales/wetlands without a USACE permit. While the USACE did not 

consider wetlands located at STM to be jurisdictional, NREL regards them as ecologically functional 

wetlands. Vegetation surveys in 2000 and 2001 at STM and the NWTC identified wetland areas 

totaling 0.3ha (0.75ac) and 0.4ha (1ac), respectively. These areas will continue to be protected for the 

benefits they provide which include water quality filtration, attenuation of stormwater flows and 

habitat for site fauna. 
NREL Environmental Performance Report- 2009 Page 65

5.14 Cultural Resources 

5.14.1 Program Management 

Cultural resources are protected under Section 106 of the National Historic Preservation Act (NHPA) 

of 1966, as amended. Significant cultural resources are either eligible for, or listed in, the National 

Register. 

Cultural resources are defined as any prehistoric or historic district, site, building, structure, or object 

considered important to a culture, subculture, or community for scientific, traditional, religious, or 

any other reason. Cultural resources can be divided into three major categories: 

Prehistoric and historic archaeological resources 

Architectural resources 

Traditional cultural resources. 

Prehistoric and historic archaeological resources are locations where human activity measurably 

altered the earth or left deposits of physical remains (e.g., arrowheads, bottles). Prehistoric resources 

that predate the advent of written records in a region range from a scatter composed of a few artifacts 

to village sites and rock art. Historic resources may include campsites, roads, fences, trails, dumps, 

battlegrounds, mines, and a variety of other features. 

Architectural resources include standing buildings, dams, canals, bridges, and other structures of

historic or aesthetic significance. Architectural resources generally must be more than 50 years old to 

be considered for protection under existing cultural resource laws. However, more recent structures, 

such as Cold War facilities, may warrant protection if they manifest the potential to gain significance 

in the future. 

A traditional cultural resource can be defined as a property that is eligible for inclusion in the 

National Register because of its association with cultural practices or beliefs of a living community 

that are rooted in the community’s history, and are important in maintaining the continuing cultural 

identity of the community. Traditional resources may include archaeological resources, buildings, 

neighborhoods, prominent topographic features, habitats, plants, animals, traditional culture. 

5.14.1.1 Site Surveys 

Three formal surveys of historic and cultural resources have been performed on the STM site. These 

surveys were completed in 1980, 1987, and 2003. Two additional surveys of the Camp George West 

district involving the STM site have also been conducted. 

As a result of these STM surveys, three historical sites were recognized as significant cultural 

resources that should be preserved. These sites include an open-air amphitheater (Figure 5.13), a 

stone bridge spanning a natural drainage channel adjacent to the amphitheater, and a stone and 

concrete ammunition bunker below the amphitheater site (Figure 5.14). The three structures were 

constructed during the Works Progress Administration era in the 1930s. Through NREL's efforts, 

these sites have been added to the National Register, with the amphitheater and stone footbridge 

listed together as a single site. NREL also participated in an interagency survey of STM and Camp 

George West to identify historic structures and sites eligible for nomination to the National Register. 

Figure 1.7 provides an aerial view of the amphitheater. 
NREL Environmental Performance Report- 2009 Page 66

The Camp George West Historic District, also listed on the National Register, includes the 25-acre 

parcel of NREL’s site, south of the DWOP. Two types of historic archaeological resources (firing 

range lines and a low rock wall) have been identified on this parcel. These resources have been 

determined to contribute to the National Register eligibility of the Camp George West Historic 

District. 

The Camp George West Historic District overlaps the NREL STM property by 25 acres. Two 

contributing resources occur within those 25 acres. Contributing resources are those features within a 

historic district that contribute to the district’s overall eligibility for the National Register. 

A 2003 cultural resource survey was conducted of the 25-acre parcel south of Denver West Parkway 

on the STM site. The survey confirmed the existence of the contributing features to the Camp George 

West Historic District occurring within the 25-acre parcel. The contributing resources are: 

Two firing lines located on the 25 acres. There are also firing lines located south of the 

NREL property on land owned by Jefferson County Open Space and proposed for 

development as the Camp George West Park. 

Portions of a low rock wall are also present on the 25 acres. There is also a rock wall located 

south of the NREL property. 

DOE consulted with the State Historic Preservation Office (SHPO) regarding the significant 

resources located on the 25 acres. DOE and the SHPO subsequently entered into a Memorandum of 

Agreement where DOE agreed to perform further surveys to fully document the resources on the 25 

acres prior to any development of the parcel. 

In 2005, DOE-GO and NREL conducted documentation of the Camp George West firing range lines 

and low rock walls, which contribute to the Camp George West Historic District’s eligibility to the 

National Register. The documentation resulted in Level II documentation from the Historic American 

Buildings Survey (HABS) and the Historic American Engineering Record (HAER) that consisted of 

mapping, photographs, and detailed description of the resources. The documentation was submitted 

using archival quality materials to the SHPO in late 2005. 

In January 2006, the Camp George West Level II HABS/HAER documentation (originally dated 

August 2005) was revised to include field drawings of the ―low rock wall‖ as requested by the 

Colorado SHPO. This was the final report submitted to the SHPO. It is on file with the Colorado 

SHPO and also at the DOE-GO and NREL offices. 

Also in CY2006, a site survey for cultural resources was conducted in support of NREL/DOE EAs 

for the first of three site development projects (RFHP, and two potential solar field sites). The RFHP 

EA was completed in early summer 2007.

An archaeological survey of the NWTC site was conducted in support of the 1996 environmental 

assessment to supplement previous surveys so there were no gaps in cultural surveys on the site. No 

significant historical or archaeological resources were identified. However, the wooded ridge area on 

the west portion of the site was identified as a location with potential for cultural resources, so further 

testing or observation during excavation would be done should there be any future need for work in 

the utility corridor in the vicinity of the ridge. 
NREL Environmental Performance Report- 2009 Page 67

5.14.2 Permitting and Requirements 

NREL has no permitting requirements for this area of environmental management. In order to 

comply with cultural resource protection requirements, NREL instructs construction contractors at 

their site orientation that in the event they discover any evidence of cultural resources during ground 

disturbing activities at the STM or NWTC sites, they are to stop all work in the vicinity until a 

qualified archaeologist evaluates the significance of the find. 

5.14.3 2009 Activities 

In 2009, construction activities continued on the Research Support Facility near the Site Entrance 

Building. During the preliminary excavations, a few items were unearthed that were reviewed under 

the Cultural Resource Management procedure; while of interest, none were found to be of unique 

value.

5.15 National Environmental Policy Act (NEPA) 

5.15.1 Program Management 

Management in this area is consistent with NREL’s NEPA Implementation Program (6-2.2). 

As a federal agency, DOE is required to comply with NEPA by evaluating the potential for 

environmental impacts prior to conducting its activities. The Council on Environmental Quality 

(CEQ) issues regulations for compliance with the Act. DOE has also issued implementing 

regulations at 10 CFR that complement the CEQ requirements. DOE has written a site-wide 

environmental assessment (EA) for its activity at the STM Site and DWOP, and separate EAs for the 

NWTC and JSF activities. 

NREL has established procedures, with the approval of the DOE-GO, to assist DOE in meeting their 

NEPA obligation. Proposed activities that will be conducted at NREL’s five sites are evaluated for 

their potential environmental effects using the appropriate level of NEPA review, in conjunction with 

DOE-GO. 

The NREL NEPA Handbook has been prepared to provide NREL project managers and procurement 

specialists with guidance on implementing the NEPA procedures, and training is provided to staff, as 

appropriate. 

5.15.2 Permitting 

NREL has no permitting requirements under NEPA. 

5.15.3 2009 Activities 

During 2009, EHS completed numerous NEPA reviews of both onsite and offsite activities through 

completion of NEPA Worksheets and NREL environmental checklists. As outlined in NREL’s 

NEPA implementation procedures, these reviews were coordinated among NREL project managers, 

subcontracting staff, the NREL NEPA coordinator, and the DOE-GO NEPA Compliance Officer. 

NEPA requirements were also coordinated with future program planning (e.g., development of 

NREL’s 2007 Grand Buildout Infrastructure Design) through interaction between NREL’s EHS 

Office director and NREL’s technology program and project managers. Requirements were also 

coordinated through participation in the NREL management annual planning process, Environmental 

Management System implementation, and other reviews of proposed projects for the upcoming FY

2010. 
NREL Environmental Performance Report- 2009 Page 68

In 2009, NREL completed the EA process for the second STM site-wide EA supplement (DOE/EA 

1441-S-2) to address proposed site development projects, including the Energy Systems Integration 

Facility (ESIF), Site Infrastructure Improvements (Phase II), South Site Entrance from South Golden 

Road, Expansion of the Waste Handling Facility, and Expansion of the Visitors Center. Also in 2009, 

planning began for extensive vegetation and wildlife surveys at the STM and NWTC sites in support 

of revisions to the site-wide EAs for each location.

In 2008, DOE issued the Final Supplement to Final Site-Wide Environmental Assessment of the 

NREL STM Complex (DOE/EA 1440-S-1), which received a Finding of No Significant Impact 

(FONSI). As a condition of the FONSI, DOE issued a Mitigation Action Plan (MAP) to address a 

DOE determination that there are potential environmental impacts from these projects that require 

mitigation to assure that the impacts do not become significant. The MAP identified steps that would 

be taken to reduce traffic impacts resulting from the transfer of approximately 800 employees to the 

new Research Support Facility. These steps, and their status, are described in Section 4.4.1, above. 

The MAP also requires that a report of the implementation and effectiveness of the STM mitigation 

measures be published in the Annual Site Environmental Report (this document). The report is to be 

published after occupation of the RSF, anticipated to be June 2010.

5.16 Radiological Program 

5.16.1 Program Management 

Management in this area is consistent with the following NREL programs: Air Quality Protection (6-

2.5) and Radiation Safety (6-4.5). All radioactive material at NREL facilities is handled according to 

NREL’s Radiation Safety Program. Elements of the program include a Radiation Safety Committee, 

a Radiation Safety Lab-Level Procedure, safe operating procedures, safe work permits, radiological 

control areas and postings, monitoring, training (Rad Worker 1: Radiation Equipment Safety and Rad 

Worker 1: Radiation Materials Safety), and purchasing controls for radioactive materials. 

There are no nuclear operations at NREL sites. All of NREL’s radiation sources are used/stored in 

facilities located on the STM site. These include three x-ray diffraction machines at the SERF and 

one at the FTLB. In addition, one laboratory at the FTLB, on the STM site, occasionally uses small 

quantities of radioisotopes for biological labeling. All x-ray generating machines are inspected 

annually. A state-licensed surveyor inspects and certifies the x-ray machines and audits NREL's 

program for radiation safety in connection with operating the machines every other year. NREL’s 

radiation safety officer conducts the inspections in alternating years.

Monitoring of equipment and facilities for removable contamination is performed in the laboratory 

where radioisotopes are used. Wipe tests are performed on any laboratory surfaces that could have 

become contaminated by the radioisotope work at least monthly and more frequently if needed. 

These wipes are analyzed using a scintillation counter. 

DOE Order 5400.5, ―Radiation Protection of the Public and the Environment,‖ established radiation 

emission limits for DOE facilities. Such emissions are also regulated by Section 112 of the Clean Air 

Act as implemented by 40 CFR 61, Subpart H, promulgated by the EPA. 40 CFR 61 established 

National Emission Standards for Hazardous Air Pollutants (NESHAPs), and, more specifically, 

Subpart H, sets such standards for radiological materials, known as Rad NESHAPs. DOE facilities, 

including NREL, must annually demonstrate compliance with the Rad NESHAP, which limits 

emissions to amounts that would prevent any member of the public from receiving an effective dose 
NREL Environmental Performance Report- 2009 Page 69

of 10 millirem (mrem) per year or greater. No radioactive air-emission monitoring is conducted at 

NREL because of the extremely low usage of radioactive material. Therefore, NREL demonstrates 

compliance with the Rad NESHAPs in 40 CFR 61, Subpart H, by utilizing the EPA’s COMPLY 

computer model to determine the effective dose equivalent to the public. 

All radioactive waste generated during NREL activities is classified as low-level waste. Waste from 

the STM site is temporarily stored at the Waste Handling Facility (WHF) until disposal is arranged at 

an offsite facility permitted to accept low-level radioactive waste. 

5.16.2 Permitting 

NREL does not have a radioactive materials license from the State of Colorado, as the laboratory is 

currently under DOE jurisdiction for radioactive materials handling.

5.16.3 2009 Activities

In 2009, NREL reported that, using the COMPLY model, the Laboratory’s effective dose equivalent 

to the public was 0.027 mrem/year, well below the Rad NESHAP limit.
NREL Environmental Performance Report- 2009 Page 70

6 Conservation Easement Lands 

In 1999, DOE granted a conservation easement for 177 acres of the STM site to Jefferson County. 

The purpose of the conservation easement is to preserve the natural character of the property, 

including its visual, biological, and recreational resources, especially in relation to the changing land 

uses adjacent to the NREL site and within the region. 

The goals of the easement are to: 

Retain, preserve, and protect natural, scenic, ecological, and historical aspects of the 

conservation easement property

Protect the ecosystem of the STM area and the sustainable habitat for diverse vegetation, 

birds, and terrestrial animals 

Ensure the scenic and biological integration with adjoining open-space land 

Prevent further industrial, commercial, or residential development of the conservation 

easement property 

Preserve the conservation easement property as natural open space. 

A baseline inventory of the property was prepared in June 1999 to document the current condition of 

the easement property and to assess the conservation value of the property (Department of Energy, 

Golden Field Office, 1999). The baseline inventory includes a description of the geographical setting 

and adjacent property owners, access and use of the property by the public, and a description of the 

existing environmental conditions of the property (geology, hydrology, vegetation, wildlife, and 

cultural resources).

Jefferson County began the development of the South Table Mountain Management Plan in 2000, 

with a final version approved by the Jefferson County Open Space Advisory Committee and the 

Board of County Commissioners in 2004.

Figure 13. South Table Mountain Conservation Easement Area.
NREL Environmental Performance Report- 2009 Page 71

6.1 2009 Property Assessment 

During 2009, there was no NREL activity on the conservation easement property having the potential 

to degrade the environmental condition of the property. Jefferson County Open Space conducts 

periodic site inspections; to date, no degraded conditions or other environmental issues were found.

Jefferson County Open Space has the responsibility to establish and maintain formal trails on the 

conservation easement property. The trail plan calls for establishing trails in phases. The first phase 

began in 2004, with Jefferson County Open Space installing two trails from Denver West Parkway 

(near the NREL Site Entrance) to the mesa top. Routine trail maintenance occurred in CY2009. The 

access trail along the NREL entrance road was improved in 2008 and again in 2009 to accommodate 

changes necessitated by construction activities.
NREL Environmental Performance Report- 2009 Page 72

7 Contacts for Feedback or More Information

We welcome your feedback and suggestions on this report and on NREL’s efforts at sustainability and 

environmental stewardship. To provide comments or to obtain additional information about NREL’s environmental 

and sustainability programs, please contact:

Maureen Jordan John Eickhoff

Director, EHS Senior Environmental Scientist

maureen.jordan@nrel.gov john.eickhoff@nrel.gov

303-275-3248 303-275-3217

National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393

303-275-3000 – www.nrel.gov

Operated for the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

by the Alliance for Sustainable Energy, LLC

NREL- October 2009
NREL Environmental Performance Report- 2009 Page 73

8 References

Armstrong, D.; Bock, C.; Piaggio, T.; Schmidt, E. (2001). NWTC Site wide Bat and Avian Impact Study Plan. May 

1, 2001-July 31, 2002.

EG&G Rocky Flats, Inc. (1992). Rocky Flats Plant Site Environmental Report, January Through December 1992. 

Golden, Colorado.

Felsburg Holt & Ullevig (2007). National Renewable Energy Laboratory South Table Mountain Facility Traffic 

Impact Study Update. Centennial, Colorado.

Handex of Colorado, Inc. (1997). Groundwater Monitoring Report, South Table Mountain Site. Golden, Colorado.

National Renewable Energy Laboratory (Draft). ES&H Program Number 6-2.12,

Weed Management Program, STM Site. Golden, Colorado.

National Renewable Energy Laboratory (1997). National Renewable Energy Laboratory Environmental Report for 

1995 and 1996. Golden, Colorado.

National Renewable Energy Laboratory (1999a). National Renewable Energy

Laboratory Five-Year Plan, 2000-2004. Golden, Colorado.

National Renewable Energy Laboratory (1999b). NREL Policy Number 6-2, Environmental Management. Golden, 

Colorado.

National Renewable Energy Laboratory (1999c). NREL Policy Number 6-6, Risk Assessment. Golden, Colorado.

National Renewable Energy Laboratory (2009a). Fiscal Year 2009 Laboratory Directed Research and Development 

(LDRD) Program.. Golden, Colorado.

National Renewable Energy Laboratory (2009b). FY2009 National Renewable Energy Laboratory Annual Report: A 

Year of Energy Transformation. Golden, Colorado.

National Renewable Energy Laboratory (2009c). Sustainability Report 2009. Golden, Colorado.

Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, 

Colorado.

Plantae Consulting Services (2002). Vegetation Survey, NREL South Table Mountain Site. Boulder, Colorado

Rust Environment & Infrastructure, Inc. (1993). Water Quality Monitoring, National Wind Technology Center. 

Englewood, Colorado.

Rust Environment & Infrastructure, Inc. (1994). Final Report, Baseline Surface Water Monitoring Program: 1993. 

Englewood, Colorado.

Rust Environment & Infrastructure, Inc. (1995a). Report, Wastewater Monitoring Program, Fourth Quarter, 1994 

and Annual Report. Englewood, Colorado.

Rust Environment & Infrastructure, Inc. (1995b). Final Report, Ground Water Monitoring, Third Quarter, 1994 and 

Fourth Annual Report, South Table Mountain Site. Englewood, Colorado.

Schmidt, E.; Piaggio, A.J.; Bock, C.E.; Armstrong, D.M. (January 2003). National Wind Technology Center Site 

Environmental Assessment: Bird and Bat Use and Fatalities – Final Report. University of Colorado, Boulder, 

Colorado.
NREL Environmental Performance Report- 2009 Page 74

Science Applications International Corporation (2005). Wildlife Survey (Including Migratory Birds and Raptors) at 

the National Renewable Energy Laboratory South Table Mountain Site, Golden, Colorado. Lakewood, Colorado.

U.S. Department of Energy (1993). Site wide Environmental Assessment for the National Renewable Energy 

Laboratory, Golden, Colorado. DOE/EA-0850.

U.S. Department of Energy (1998). Environmental Assessment, Right-of-Way Easement For Public Service 

Company of Colorado at the South Table Mountain Site, Golden, Colorado. DOE/EA-1254.

U.S. Department of Energy (2002). Site-Wide Environmental Assessment of National Renewable Energy 

Laboratory’s National Wind Technology Center. DOE/EA 1378.

U.S. Department of Energy (2003). Site-Wide Environmental Assessment of the National Renewable Energy 

Laboratory’s South Table Mountain Complex. DOE/EA 1440.

U.S. Department of Energy (2007). Final Environmental Assessment of Three Site Development Projects at the 

National Renewable Energy Laboratory South Table Mountain Site. DOE/EA 1573.

U.S. Department of Energy (2009). Annual Energy Outlook 2009. DOE/EIA 0380(2009).

U.S. Department of Energy, Golden Field Office (1999). National Renewable Energy Laboratory (NREL) Site 

Conservation Easement Baseline Inventory. Golden, Colorado. 

Western Ecosystems Technology, Inc. (2009) Study Plan: Monitoring Avian Use and Mortality at the National Wind 

Technology Center.
NREL Environmental Performance Report- 2009 Page 75

9 Appendices

Appendix A – Summary of NREL Environmental Permits, Registrations, Notifications

Appendix B – Wildlife Species Observed on the STM Site
NREL Environmental Performance Report- 2009 Page 76

Appendix A – Summary of NREL Environmental Permits, Registrations, Notifications

Table 1. Summary of NREL Environmental Permits, Registrations, Notifications

Category Permit or 

Registration 

Number

Permit or Reg 

Holder

Permit Type Permit Description Issuing Agency Status

Permit 99JE0400 NREL/DOE Air TCPDU air emissions Colorado Dept. of Public 

Health and Environment

Active

Permit 07JE0277 DOE Air Stationary Source Construction (RFHP) Colorado Dept. of Public 

Health and Environment

Active

Permit 08JE0889L DOE Air Air Emission Permit for Land 

Development (fugitive dust from 

construction activities)

Colorado Dept. of Public 

Health and Environment

Active

Permit 10JE1400 DOE Air Air Emission Permit, Air Pollution 

Emission Notice (APEN)

Colorado Dept. of Public 

Health and Environment

Active

Notification 

and 

Registration

001 and 002 DOE Air: Ozone 

Depleting 

Substances

Registration of stationary appliances (2 

SERF chillers)

Colorado Dept. of Public 

Health and Environment

Active

Notification 

and 

Registration

N/A DOE Air: Ozone 

Depleting 

Substances

Facility Notification - CFCs Colorado Dept. of Public 

Health and Environment

Active

Notification 

and 

Registration

N/A DOE Air: Ozone 

Depleting 

Substances

Registration of stationary appliance Colorado Dept. of Public 

Health and Environment

Active

Permit AFP-CO-00255 DOE Alcohol Alcohol Producer's Permit U. S. Department of the 

Treasury

Active

Permit TF-CO-0331 DOE Alcohol Industrial Alcohol User Permit U. S. Department of the 

Treasury

Active

Notification 

and 

Registration

2873-1 Alliance for 

Sustainable 

Energy, LLC

Aboveground 

Storage Tank

Annual registration for AST greater than 

660 gallons

Colorado Department of Labor 

and Employment

In Service

Notification 

and 

Registration

2873-2 Alliance for 

Sustainable 

Energy, LLC

Aboveground 

Storage Tank

Annual registration for AST greater than 

660 gallons

Colorado Department of Labor 

and Employment

In Service
NREL Environmental Performance Report- 2009 Page 77

Category Permit or 

Registration 

Number

Permit or Reg 

Holder

Permit Type Permit Description Issuing Agency Status

Notification 

and 

Registration

PWSID Number 

CO0230860

DOE Drinking Water Non-community Supply of hauled water 

from a surface water source

Colorado Dept. of Public 

Health and Environment

Active

Permit 37232 SERI GW Monitoring 

Well

Permit to Construct a Well (MW-1) Colorado Department of 

Natural Resources

Active

Permit 37229 SERI GW Monitoring 

Well

Permit to Construct a Well (MW-2) Colorado Department of 

Natural Resources

Active

Permit 37228 SERI GW Monitoring 

Well

Permit to Construct a Well (MW-3) Colorado Department of 

Natural Resources

Active

Permit 37231 SERI GW Monitoring 

Well

Permit to Construct a Well (MW-4) Colorado Department of 

Natural Resources

Active

Permit 37230 SERI GW Monitoring 

Well

Permit to Construct a Well (MW-5) Colorado Department of 

Natural Resources

Active

Notification 

and 

Registration

CO4890000017 DOE Hazardous Waste Notification of Regulated Waste Activity Colorado Dept. of Public 

Health and Environment

In Effect

Notification 

and 

Registration

CO3890090076 DOE Hazardous Waste Notification of Regulated Waste Activity Colorado Dept. of Public 

Health and Environment

In Effect

Notification 

and 

Registration

COD980805162 DOE Hazardous Waste Notification of Regulated Waste Activity Colorado Dept. of Public 

Health and Environment

In Effect

Notification 

and 

Registration

COD983802448 DOE Hazardous Waste Notification of Regulated Waste Activity Colorado Dept. of Public 

Health and Environment

In Effect

Notification 

and 

Registration

COR000207563 DOE Hazardous Waste Notification of Regulated Waste Activity Colorado Dept. of Public 

Health and Environment

In Effect

Permit 2213 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active

Permit 2214 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active
NREL Environmental Performance Report- 2009 Page 78

Category Permit or 

Registration 

Number

Permit or Reg 

Holder

Permit Type Permit Description Issuing Agency Status

Permit 2209 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active

Permit 2211 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active

Permit 2215 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active

Permit 2212 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active

Permit 2210 NREL HazMat Hazardous material storage and use 

permit

West Metro Fire Rescue Active

Notification 

and 

Registration

93000378 DOE Historic 

Registration

National Register of Historic Places National Park Service No Expiration

Notification 

and 

Registration

93000379 DOE Historic 

Registration

National Register of Historic Places National Park Service No Expiration

Notification 

and 

Registration

85936 NREL Registration X-Ray Machine Certification Report Colorado Dept. of Public 

Health and Environment

Active

Notification 

and 

Registration

85938 NREL Registration X-Ray Machine Certification Report Colorado Dept. of Public 

Health and Environment

Active

Notification 

and 

Registration

92056 NREL Registration X-Ray Machine Certification Report Colorado Dept. of Public 

Health and Environment

Active

Notification 

and 

Registration

85937 NREL Registration X-Ray Machine Certification Report Colorado Dept. of Public 

Health and Environment

Active

Permit COR10CY5F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10CY6F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active
NREL Environmental Performance Report- 2009 Page 79

Category Permit or 

Registration 

Number

Permit or Reg 

Holder

Permit Type Permit Description Issuing Agency Status

Permit COR10D88F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10DH3F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10DH4F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E21F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E20F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10DA6F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10DA5F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E08F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E09F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E12F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E10F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10DD2F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10DD1F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active
NREL Environmental Performance Report- 2009 Page 80

Category Permit or 

Registration 

Number

Permit or Reg 

Holder

Permit Type Permit Description Issuing Agency Status

Permit COR10DB4F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E06F Alliance for 

Sustainable 

Energy, LLC

Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10E07F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Permit COR10CT8F DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active 

Permit COR10CiOF DOE Stormwater Construction General Permit 

(Stormwater) COR10000F

U. S. Environmental Protection 

Agency

Active

Notification 

and 

Registration

062008550086QS Midwest 

Research 

Institute

Transportation Hazardous Material Transportation U. S. Department of 

Transportation

Active

Notification 

and 

Registration

Army Corps File# 

NWO-2009-1014-

DEN

Alliance for 

Sustainable 

Energy, LLC

Wetlands Jurisdictional Determination for Lena 

Gulch

U. S. Army Corps of Engineers Active

Notification 

and 

Registration

Army Corps File# 

NWO-2009-1014-

DEN

Alliance for 

Sustainable 

Energy, LLC

Wetlands Jurisdictional Determination for Lena 

Gulch

U. S. Army Corps of Engineers Active

Permit 10-106216GB DOE Earth Disturbance Grading permit Jefferson County Active

Notification 

and 

Registration

PSWID 

CO0230860

DOE Drinking Water Operator in Responsible Charge Colorado Dept. of Public 

Health and Environment

Active
NREL Environmental Performance Report- 2008 Page 81

Appendix B – Wildlife Species Observed at NREL’s STM Site

The following is a list of common and scientific names of wildlife species observed during wildlife surveys at the 

National Renewable Energy Laboratory’s South Table Mountain site in Golden, Colorado.

Table 2. Wildlife Species Observed at NREL’s STM Site

Common Name Scientific Name

Reptiles

Bull snake1 Pituophis catenifer

Plains garter snake Thamnophis radix

Six-lined racerunner Cnemidophorus sexlineatus

Tiger salamander Ambystoma tigrinum

Western rattlesnake Crotalus viridus

Birds

American crow Corvus brachyrhynchos

American kestrel Falco sparverius

American robin Turdus migratorius

American tree sparrow Spizella arborea

Barn swallow Hirundo rustica

Black-billed magpie Pica pica

Black-capped chickadee Poecile atricapilla

Black-crowned night heron Nycticorax nycticorax

Blue jay Cyanocitta cristata

Brewer's blackbird Euphagus cyanocephalus

Brown headed cowbird Molothrus ater

Bullock's oriole Icterus bullockii

California gull Larus californicus

Canada goose Branta canadensis

Cedar Waxwing Bombycilla cedrorum

Common nighthawk Chordeiles minor

Common raven Corvus corax

Common snipe Gallinago gallinago

Cooper’s hawk Accipiter cooperii

Dark-eyed junco Junco hyemalis

Downy woodpecker Picoides pubescens

European starling Sturnus vulgaris

Flycatcher Empidonax sp.

Golden eagle Aquila chrysaetos

Great blue heron Ardea herodias

Horned lark Eremophila alpestris

House finch Carpodacus mexicanus

House sparrow Passer domesticus

Killdeer Charadrius vociferous

Lark bunting Calamospiza melanocorys

Loggerhead shrike Lanius ludovicianus

MacGillivray’s warbler Oporornis tolmiei

Mallard Anas platyrhynchos

Mountain bluebird Sialia currucoides

Mourning dove Zenaida macroura

Northern flicker Colaptes auratus

Northern harrier Circus cyaneus

Osprey Pandion haliaetus
NREL Environmental Performance Report- 2008 Page 82

Common Name Scientific Name

Prairie falcon Falco mexicanus

Red-breasted nuthatch Sitta canadensis

Red-tailed hawk Buteo jamaicensis

Red-winged blackbird Agelaius phoeniceus

Rock dove Columba livia

Rock wren Salpinctes obsoletus

Say's phoebe Sayornis saya

Sharp-shinned hawk Accipiter striatus

Spotted towhee Pipilo maculates

Swainson’s hawk Buteo swainsoni

Tree swallow Tachycineta bicolor

Turkey vulture Cathartes aura

Vesper sparrow Pooecetes gramineus

Western kingbird Tyrannus verticalis

Western meadowlark Sturnella neglecta

Western scrub jay Aphelocoma californica

White-crowned sparrow Zonotrichia leucophrys

Mammals

Black-tailed jackrabbit1

Lepus californicus

Bushy-tailed woodrat1 Neotoma cinerea

Coyote Canis latrans

Deer mouse Peromyscus maniculatus

Fox squirrel Sciurus niger

Long-tailed weasel Mustela frenata

Mexican woodrat Neotoma mexicana

Mountain cottontail Sylvilagus nuttalli

Mule deer Odocoileus hemionus

Prairie vole Microtus ochrogaster

Raccoon Procyon lotor

Red fox Vulpes vulpes

Western harvest mouse Reithrodontomys megalotis 

White-tailed jackrabbit Lepus townsendii

Yellow-bellied marmot1 Marmota flaviventris